Feature Article: Waste Minimization Plans: Requirements, Benefits, & Strategies

Posted on 10/26/2011 by James Griffin

The Manifest Signature
When you sign a hazardous waste manifest, you are promising two things. One that you have followed all of the Department of Transportation’s regulations for packaging and shipping hazardous materials. And two, that you are minimizing your waste. 
Additional Certification
According to the Hazardous Waste Manifest and Instructions (Appendix to 40 CFR Part 262) before you can ship your waste away: “The generator [you] must read, sign, and date the waste minimization certification statement. In signing the waste minimization certification statement, those generators who have not been exempted by statute or regulation from the duty to make a waste minimization certification under section 3002(b) of RCRA are also certifying that they have complied with the waste minimization requirements.” The actual text of the statement is: “I certify that the waste minimization statement identified at 40 CFR 262.27(a) (If I am a large quantity generator) or (b) (If I am a small quantity generator) is true.
Waste Minimization Planning Mandated
Such a short and obtuse line can be easily missed, and often is. What are you actually promising when you sign on the dotted line? The full text of the waste certification statement is at 40 CFR 272.27, subsection 262.27(a) for large quantity generators, and subsection 262.27(b) for small quantity generators. 
Subsection (a) reads: 
“I am a large quantity generator. I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically practicable and I have selected the practicable method of treatment, storage, or disposal currently available to me which minimizes the present and future threat to human health and the environment.” 
Subsection (b) reads: 
“I am a small quantity generator. I have made a good faith effort to minimize my waste generation and select the best waste management method that is available to me and that I can afford.”
Benefits of a Waste Minimization Plan
Beyond simply complying with regulatory mandates, a waste minimization plan can create a positive environmental impact and save your company money through more efficiently managing the lifecycle of your chemicals. A better managed inventory and closer lifecycle management of your chemicals can reduce the costs associated with purchasing; inventory control; and waste management—including off-site transportation, treatment, and disposal.
Plus, “good will” and an improved corporate image will add to your company’s value. Developing and executing a plan can help you reach your Six Sigma goals and qualify for ISO certifications. An enhanced image can attract new clients and retain those with certain environmental requirements for their clients and vendors. 
A good waste minimization plan as part of your overall environmental management system will also improve your relationship with the public, regulators, lenders, and investors.
Resources for Developing Your Plan
Environmental Management System (EMS)
The Environmental Protection Agency has some excellent resources to help you develop a comprehensive Environmental Management System. “An EMS is a continual cycle of planning, implementing, reviewing and improving the processes and actions that an organization undertakes to meet its business and environmental goals.” Visit for general information
Conserving Resources, Preventing Waste
The EPA supports “WasteWise,” a free program for organizations to eliminate solid waste and certain industrial wastes. The program can help you with reducing your waste generation and with recycling initiatives. Be sure to check your own state’s environmental agencies’ Web site for recycling programs and chemical exchange lists.
Waste Minimization Tools
 In addition, the EPA offers waste minimization tools at its Web site.
  • Chemical Management Services—A business model in which the service provider is paid based on the quality and quantity of services provided, not on the volume of chemicals sold. Chemical management services reduce chemical lifecycle costs, risks, and environmental impacts. 
  • Energy Recovery—Converting waste into useable fuel. 
  • Frequent Questions—About waste minimization. 
  • National Lead Free Wheel Weight Initiative (NLFWWI)—Reducing the amount of lead deposited on national roadways by providing safe alternatives for lead tire weights. 
  • Lean Manufacturing—A business model that focuses on eliminating waste while delivering quality products at the lowest cost to the manufacturer and consumer. 
  • Technical Assistance—Programs provide information, advice, and, in some cases, hands-on technical assistance to companies seeking cleaner, cheaper, and smarter environmental solutions.

Tags: hazardous, manifests, RCRA, waste, waste minimization

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