Life Cycle Assessment is a critical tool for organizations seeking ways to reduce their environmental impact, manage waste more efficiently, and reduce compliance costs. Also called life cycle analysis or “cradle-to-grave” analysis, a Life Cycle Assessment (LCA) is designed to gauge how a product will impact the environment throughout its life—from the initial sourcing of raw materials to eventual waste disposal.
By incorporating “life-cycle” thinking into standard operating procedures (SOPs), organizations can reduce overall costs related to inventory acquisition, waste generation and management, the off-site shipment of waste, and its treatment or disposal. Often, policies and procedures that bring together purchasing departments, manufacturing units, and hazardous waste management departments produce dramatic inventory savings and a reduction in waste-related spending and reduce negative environmental impacts resulting from wastewater discharges, dangerous air emissions, landfilling or incineration, and other treatments.
To perform an LCA, organizations should evaluate the chemicals and other materials they use through four major life-cycle phases:
Use in manufacturing, maintenance, or R&D;
Recycling processes; and
Waste management, including on-site storage, off-site shipping, treatment, and/or disposal.
Procurement or Purchasing
By implementing a screening process to ensure purchasing requests are vetted, you can reduce the quantity of unused chemicals that become waste and consider substitutions that are less toxic. Always consider the “greener choice” when quality control specs allow for this option.
Manufacturing, Maintenance, or R & D
Look at your manufacturing/production processes, maintenance schedule and protocol, and laboratory practices to identify changes that you can make to minimize the volume and toxicity of waste generated.
Recycling and Reuse
For hazardous waste facilities operating under the 90-/180-/270-day rules, the recycling process itself is exempt from RCRA regulation. That also means that obtaining a RCRA permit is not necessary to recycle on site (State RCRA regulations may vary; see 40 CFR 261.6(c)). An added benefit is that recycled materials that are produced from recycling wastes that were already counted in the same month are not counted a second time when they become waste again (see 261.5(d)). In addition, the hazardous waste regulations provide a built-in relief for reusing materials in certain ways that exclude them from the definition of solid waste (see 40 CFR 261.2(e)).
“An ounce of prevention is worth a pound of cure”. The best scenario is to not generate the waste to begin with, but if it has been generated, then an aggressive recycling program (on- or off-site) is environmentally prudent.
Much of the costs associated with chemical management occur on the backend; it’s a problem many employees upstream are not aware of. Inventory management systems (e.g., bar codes, approvals, etc…), the creation of “haz marts” for the redistribution of still viable materials, charge-back policies (i.e., requiring departments using chemicals to pay for the off-site shipment, treatment, and disposal of their waste), periodic monitoring, reassessing SOPs, and incorporating these issues into your company-wide training classes are good management practices.
The following resources from the U.S. EPA may help you develop your LCA:
The EPA’s National Risk Management Research Laboratory (NRMRL) maintains a guide to performing Life Cycle Assessment (LCA) on its website.
The Comprehensive Procurement Guideline (CPG) program is part of EPA’s continuing effort to promote the use of materials recovered from solid waste. Buying recycled-content products ensures that the materials collected in recycling programs will be used again in the manufacture of new products. Currently, there are 61 products designated in eight categories.
The National Waste Minimization Program “supports efforts that promote a more sustainable society, reduce the amounts of waste generated, and lower the toxicity and persistence of wastes that are generated.” The program focuses on reducing 31 priority chemicals found in products and wastes by addressing methods to eliminate or reduce their use by reclamation or reuse.
EPA’s Design for the Environment Program “helps consumers, businesses, and institutional buyers identify cleaning and other products that perform well, are cost-effective, and are safer for the environment.”
Learn More Ways to Cut Costs
Learn more ways to streamline your operations, minimize the waste your facility generates, and lower costs at the Advanced Hazardous Waste Management Workshop. Designed for experienced hazardous waste managers, this two-day workshop satisfies the U.S. EPA’s annual training requirement and covers the critical RCRA rules for managing waste on site.