Waste Management Principles for Manufacturing Facilities
Managing a manufacturing facility always comes with a number of challenges that must be met on a routine basis—this is true no matter the industry in question. Often, the facility generates or utilizes a large amount of industrial waste as part of its normal operations, and all this material must be handled carefully to avoid harm to human beings as well as the environment. It goes without saying, then, that waste material of this nature cannot simply be tossed into the trash like a used paper cup. The handling of industrial waste materials is governed by a number of laws and regulations. Current industry practices have been designed specifically with these rules in mind.
If you’re a professional responsible for managing industrial waste at a manufacturing facility, the best policy is to become very familiar with this network of laws and procedures. With that in mind, let’s take a look at some basic ideas and pertinent legislation that relate to the world of industrial waste management.
Definitions of Hazardous Waste
Hazardous waste takes a wide variety of forms, from common household batteries to radioactive sludge found in nuclear plants, and varies wildly in the level of threat it poses to the health of human beings, animals, and the environment as a whole. For purposes of this discussion, though, we’ll concentrate on materials produced through manufacturing processes. This type of waste can be found in gas, liquid, or solid form. When disposed of improperly, industrial waste may pollute soil or groundwater, to the detriment of organisms encountering it.
Hazardous waste is more formally defined by the Environmental Protection Agency (EPA), the federal entity responsible for monitoring the management of these industrial materials in the U.S. Specifically, the EPA regards waste as hazardous, and subject to laws governing the management of such materials, if it is found to conform with potentially dangerous characteristics in at least one of the following categories.
Ignitability – The EPA classifies as hazardous a variety of solid materials that can ignite under certain conditions. Liquids with a flashpoint under 60°C (140°F) are hazardous under EPA guidelines. Non-liquid solids that ignite under “standard temperatures” due to friction, chemical changes, or absorbing moisture are to be considered hazardous as well. In addition, all oxidizers and ignitable compressed gases are classified as hazardous. Examples of materials in this category include methanol and ethyl acetate.
Corrosivity – Materials can be classified as hazardous due to their corrosive properties. Specifically, an aqueous material is hazardous if its pH is (a) less than or equal to 2 or (b) more than or equal to 12.5, while a liquid falls under this classification if it is capable of corroding steel at a rate exceeding 6.35 millimeters per year at a temperature of 55°C (130°F).
Reactivity – Materials are to be classified as hazardous if they react to contact with water by generating toxic fumes, creating an explosive mixture, or demonstrating another kind of violent response. Additionally, materials that can detonate also fall under this category.
Toxicity – Any solid industrial waste is hazardous if it contains a level of contaminants that exceed EPA guidelines. The specific concentration of maximum allowable contaminants depends on the particular material in question, and it is important to consult the EPA’s official chart (which is printed in 40 CFR 261.24) for data on each substance in question.
Further explanation of these definitions can be found in Title 40, Part 261 of the Code of Federal Regulations (CFR).
State and Local Laws
The EPA is widely known for its role in enforcing federal environmental standards, and a lot of people naturally assume that this agency is the ultimate authority on all matters pertaining to the handling of hazardous industrial waste. This is not so, however. In some instances, environmental issues have been left to state and local agencies—and their guidelines can be significantly stricter than the federal standards. Therefore, it is essential for waste management professionals to acquaint themselves not only with EPA guidelines (including the Resource Conservation and Recovery Act of 1976, which constitutes the basis for these rules) but any applicable local regulations as well. These state and local laws are too numerous to list in the space we have available here, so you’ll have to do a little research.
Tracking Industrial Waste
You need to be aware of all forms of industrial waste present on the premises and under your responsibility, but this can be much easier said than done. You can save yourself a lot of trouble, however, by familiarizing yourself with the kinds of materials that potentially fall under the EPA’s hazardous waste guidelines. This will enable you to make correct decisions about what needs to be carefully disposed of in conformity with EPA rules, and what can be discarded via conventional methods.
You should be aware of all manufacturing materials brought into the facility. That means you need to be involved with, or at least able to observe, the purchasing of materials associated with industrial processes. One particularly useful resource for this task is the safety data sheet (SDS) that generally comes with these materials. The SDS should contain a wealth of information about the chemical and physical properties of materials used in your facility’s manufacturing process.
Furthermore, you should also become well acquainted with the manufacturing processes at your facility. Certain hazardous wastes can be created by the manufacturing process itself, even if all constituent components involved are non-hazardous in nature. If you can’t be certain whether a particular manufacturing byproduct is hazardous, then it’s always an option to contact a laboratory or an industrial waste management company to help you make a determination. They can do this by carefully analyzing a sample of the waste product in question. This is also a sound idea if the SDS attached to any given order is unclear to you.
In any event, making wild guesses is never advisable—remember that FDA infractions carry substantial penalties. Attempting to save a little time and money in the short term may easily result in a lot of long-term problems.
The Land Disposal Restrictions Program
Once you have accurately identified the hazardous waste on the premises for which you are responsible, now what? How can you dispose of them in a manner that does not violate FDA standards? Again, it’s best to know what these standards are. The Land Disposal Restrictions (LDR) Program was passed by the U.S. Congress in 1984 to bolster the environmental protections of the RCRA. The center of the LDR Program is three “prohibitions” that restrict the right of hazardous waste generations to discard materials that may damage the environment. We’ll summarize the three prohibitions here:
The Disposal Prohibition – This states that hazardous materials must be properly treated prior to disposal. These prohibitions are classified according to the type of waste in question (ignitable, corrosive, etc.). The list of acceptable treatments is too long to discuss here, but can be found Title 40, Section 268.40 of the Code of Federal Regulations (CFR). Bear in mind that materials not specifically listed in the Code are still subject to its authority if these materials exhibit characteristics of hazardous waste.
The Dilution Prohibition – This states that companies cannot attempt to comply with LDR Program rules by simply diluting hazardous waste materials as a way to avoid proper treatment procedures.
The Storage Prohibition – This states that companies can temporarily store hazardous waste only when it is necessary to amass enough material for a proper treatment or disposal procedure.
As you can see, hazardous waste management is multi-faceted in nature. That’s why it’s best to consult experienced professionals who can help you with proper waste handling procedures. Please contact National Environmental Trainers for HAZWOPER training classes and related resources.