Does your site discard unused commerical chemical products (CCPs)?
Many chemical products and formulations are identified as hazardous waste
with a P- or U-code and/or because they exhibit one or more of RCRA’s four hazardous waste characteristics—ignitability, corrosivity, reactivity or toxicity.
This can include products like:
- Cleaning solvents
- Glues and adhesives
- Paints and coatings
- Production ingredients
By thinking critically about how you manage these products at your site, you can optimize your ordering, use, and disposal practices to prevent these chemicals from entering RCRA’s jurisdiction in the first place.
Meet EPA's annual hazardous waste training mandate. The RCRA Hazardous Waste Management Workshop returns to Houston, Dallas, Detroit, Pittsburgh, Cleveland, and Cincinnati in May 2019.
Waste Minimization Strategy 1: Inventory Management
By managing your inventory properly, you can significantly reduce this waste stream. Consider these strategies:
- Centralize purchasing! If employees have carte blanche to buy whatever they want, it is certain there will be duplication, overages, and spoilage.
- Establish a digital inventory tracker for the company intranet so workers know what’s on-hand elsewhere onsite.
- Create a “haz-mart” for unwanted inventory where workers can “purchase” chemicals and products for use-at-home. This can be a physical location or a virtual listing.
- Connect purchasing with your company’s waste management and production divisions so everyone is on the same page.
- Institute a bar coding system that is integrated with a “just-in-time” automatic purchasing plan.
Waste Minimization Strategy 2: Materials Exchanges
A lot of CCP is discarded because it is expired or off-spec. That problem can be minimized by stocking shelves properly and adhering to a first-in, first-out policy. Be careful of how your standard operating procedures (SOPs) are worded.
If your SOPs state the expiration date signals the material is destined for disposal, it means the product becomes a waste on that day and must be appropriately managed. However, the EPA does not require you to automatically discard a material as of its expiration date.
What are some options, then, for managing your unwanted materials, that don’t get them regulated as waste?
You may hold on to them for later use. Or donate or sell them. To find someone who wants them, visit this website to link to more than 50 waste exchange lists across the country: mxinfo.org/list.cfm
The Materials Exchange Information website:
- Acts as a central repository and resource for information regarding materials exchanges; and
- Provides easy-to-use tools so that materials exchange managers can keep their information up-to-date.
Waste Minimization Strategy 3: Take-Backs
Finally, see if the manufacturer of a product will take it back. Even if they do so without refunding what you paid, returning chemicals can still be a cost-saving option compared to treatment and disposa
Even when the product must be reworked to recover a usable component (i.e., reclaimed), a bonus of this option is the CCP is excluded as a solid waste when reclaimed, and therefore, by definition, cannot be a hazardous waste. [40 CFR 261.2(c)(3)]
Join Us for RCRA Training in Midwest Cities
Meet EPA’s annual training mandate and keep your expertise up to date with recent revisions to the RCRA regulations under EPA’s “Generator Improvements Rule.” Join us for the RCRA workshop long-considered the "Gold Standard" in hazardous waste management training for US facilities.
The RCRA Hazardous Waste Management Workshop
comes to Grand Rapids, Chicago, St. Louis, Pittsburgh, Cleveland, Detroit, and more in April and May. See the full 2019 schedule here.