The following ideas, while not requirements, have worked at other companies. They may help make compliance (and your job) easier.
Container Management Tips
Reevaluate your storage area.
- Make your storage area user-friendly by having enough aisle space and designated, labeled areas for storage.
- Make waste storage requirements meaningful by showing your employees how it applies to their work and protects their health and safety.
- Discuss different storage options with your employees; their input into the process could be the key to making it work.
Practical approaches to container storage.
- Choose a container that is compatible with your waste, fits your storage area and is practical to use. Contact your shipping company for their requirements.
- Decrease the potential for spills by storing waste in the container it will be shipped in.
- Create an example Hazardous Waste label for use as a template.
- Place all labels on the same side of the container, facing out for easy identification.
- Keep your labels legible by not putting them directly under the bung or protect them with a plastic pouch, varnish or clear tape.
- Let employees help select the type of closure devices that will work best for them (i.e. safety funnels, open head drums or regular bungs).
- Make weekly container inspections a habit by incorporating them into other weekly activities, like routine maintenance.
Good housekeeping pays off.
- Recycle all your empty or unwanted containers, getting rid of any container that is in poor condition immediately.
- Keep your empty containers neat and organized. Remove or spray paint over old labels. If you store them outside, put them on their sides to prevent accumulation of rain or snow.
- To prevent accidental mixing, store waste containers separately from product containers.
- Appoint someone to periodically check for unwanted items to keep them from becoming a problem for your business.
Waste Disposal Tips
Research your alternatives.
- On-site disposal is allowable for certain wastes. Acids and bases can be neutralized and sewered, used oil can be burned on-site, and silver can be recovered from used photo or x-ray fixers.
- For waste disposal, pricing shouldn't be your only consideration. Become familiar with your transporter's and facility's business practices by asking them questions about waste management, handling and disposal.
Prepare ahead of time to make a waste shipment.
- Make an inventory of your containers before you call for disposal.
- Make your arrangements 60-90 days in advance which gives you enough time to complete any testing or paperwork.
- Make sure that all labels are still readable and well attached.
- Keep an example of a properly completed manifest to use as a guide.
Record Keeping Tips
Organization makes the job easier.
- File your paperwork so it's easy for others to find and use.
- Create a system that works for you. One method is to use different files for each waste stream with the records filed by date. Another way is to use tabbed 3 ring binders to separate records; this could include "pending" areas (waiting for the facility copy of the manifest) and "complete" areas.
- If you file your shipping records with your monthly invoices, make a copy for a "waste only" file. It makes your records more accessible.
- Lastly, keep up with this paperwork. It's easy to fall behind and hard to catch up.
For more information, call 651.266.1199 or AskEH.
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