One Time Episodic Event Waste Generation
You've decided you're going to do a little "House Cleaning" or perhaps you've been hit with a cleanup you were not expecting? In either case this sort of event usually leaves one to wonder do I need to let the USEPA know about what is about to occur. We are here to help you!
Handling a one-time clean-out event with the United States Environmental Protection Agency (EPA) involves several steps to ensure compliance with environmental regulations set in place both at a federal level as well as a local one. Below are some points we feel it is best to point out as a general outline of the waste clean up process:
Determine the Need of this Event: Assess the scope and nature of the clean-out event. Is this a planned event such as a one time clean-out (Commonly called an Episodic Event) or is this an event that occurred as the result of some sort of accident that happened such as a chemical spill. Identify the types of waste or hazardous materials involved and their potential impact on the environment as well as others in the immediate area and this includes animals as well.
Contact the USEPA Don't Be Afraid, They are There to Help: Reach out to the USEPA or your local state's EPA and inform them about the clean-out/up event and seek guidance on the necessary permitting or notifications you must have in place prior to the event. You can contact the appropriate regional EPA office or the EPA's emergency response hotline for immediate assistance.
Compliance Research: Research and familiarize yourself with relevant federal, state, and local regulations regarding hazardous waste management, hazardous materials, and clean-up activities. Ensure you understand the specific requirements applicable to your situation.
Develop a Plan: Create a comprehensive clean-out plan that includes waste identification or inventorying of waste, containment/containerizing the product, transportation, disposal, and any necessary remediation measures that must occur after the waste has been removed to return the site to a "Clean State". Consider hiring a professional environmental consultant such as ADCO to assist you with the planning process.
Obtain Necessary Permits: Determine if you need any permits or authorizations from the USEPA or other local regulatory agencies. This may include hazardous waste generator permits, transport manifests, or special approvals for disposal sites. Follow the application process and provide all required documentation.
Waste Management: Implement proper waste management procedures to handle and store the waste generated during the clean-out event. Ensure compliance with labeling, containment, and storage requirements for hazardous materials. Google is a great resource to use when seeking advice on a particular chemical in question. Many times Material Safety Data Sheets now referred to as just Safety Data Sheets (SDS's) can be found on Google by typing in the name of the product then MSDS after it on a Google search and many times the chemical's SDS will come right up and inform you about how to handle the product, how to dispose of it, any potential hazards you should be aware of when dealing with this product, as well as the proper USDOT shipping name.
Transportation of Waste: Arrange for appropriate transportation of the waste materials to approved treatment or disposal facilities also commonly referred to as TSDFs. Follow all regulations regarding packaging, labeling, and manifesting of hazardous waste for transportation. Keep records of all waste shipments for at least 7 years. Some records should be kept indefinitely. It is highly recommended to scan all appropriate documents and store these "In the cloud" so in the event there is a fire or other catastrophic event at your facility, you can still have access to your records through an outside source where they are kept safe.
Disposal / Treatment: Dispose of or treat the waste materials in accordance with EPA regulations and permits. Ensure you use authorized facilities capable of handling the specific types of waste generated. Keep records of disposal or treatment documentation. It is not recommended you be treating your waste if you are not licensed to do so. In many states, treatment of waste does require a special type of license and most company insurance policies will not cover you if you are operating outside your scope of work as defined with your policy writer.
Reporting: Report any spills, accidents, or incidents that occur during the clean-out event to the USEPA and any other relevant regulatory agencies as required by law. Provide detailed information about the nature of the incident, response actions taken, and any necessary remediation efforts. It is always recommended to take photos of the incident for record of the incident. It is always best to tell the regulators first rather than let them find out after the fact as this can lead to huge fines and possible loss of your business license.
Post-Clean-Out Evaluation: Once the clean-out event is complete, evaluate the effectiveness of the process, identify any lessons learned, and consider implementing improvements to prevent similar situations in the future.
It's important to note that the specific requirements and procedures may vary depending on the nature of the waste, your location, and other factors therefore, it's crucial to consult with the USEPA and other relevant regulatory agencies to ensure compliance with all applicable regulations and guidelines. The staff at ADCO stands by ready to assist you with determining what course of action is best to take for the event that has presented itself to you either intentionally or by accident.