SPECS 3.16 Miller

Complying with Waste Management Requirements

in RetailPresented by

Wade Miller, CHMM, CPEA, Exemplar Global Lead Auditor

15 March 2016

2016 copyright of convergence consulting LLC

• Hazardous vs Non-Hazardous Waste• Regulatory Requirements for Waste Management• Managing Waste Products• Sending the Waste Products to the Right Place• Keeping Records• Reporting Requirements

Agenda

Objectives

• Contractors and Vendors will understand the operational needs/constraints in managing hazardous waste at retail locations

• Retailers will engage with vendors on how they interact with the store’s waste management processes

• Spur discussions on better collaboration in managing hazardous waste between retailers and their vendors.

Where Retail Waste Comes From

1. In-store damage, recalls, clearance, damaged upon receipt, product expiration.

2. Store Operations: maintenance, instore equipment, housekeeping

3. Customers: Returns, waste left onsite (trash, parking lots, others), and recycling.

4. Construction and Remodel: includes re-lamps, display changes, other renovations.

Hazardous Waste 101

• When something is no longer going to be used for its intended purpose, it is considered a waste.– Products sold on the shelves of retail stores may

not be thrown in the trash when it expires, is damaged, or otherwise no longer sellable.

– Donation or salvage may be an option, but be careful: an unusable product sent to a charity or salvage is considered illegal management of waste.

– Construction waste is subject to the same rules

Waste the Definitions

• EPA is the Federal Agency responsible for the rules governing waste management.

• The Resource Conservation and Recovery Act (RCRA) Enacted in 1976

EPA and The States

source: NOAA

Love Canal andCuyahoga River in Ohio:The use of the Cuyahoga River for industrial dumping highlighted the need to ensure that hazardous wastes are not allowed to be released to the environment.

States Authorized to Administer

source: EPA

• Some wastes may have other uses or have specific exemptions or alternate management requirements:

• Examples include: Scrap Metal, Used Oil, Universal Wastes (batteries, lamps, pesticides and in some states, electronics).

• If a product is not able to be used as a product and doesn’t meet the exemptions (or special waste noted above), then it has to be evaluated to determine if it is hazardous or not.

Waste or Not?

• US EPA requires that wastes are hazardous if the waste is:- Ignitable: flashpoint > 141 Degrees F = D001- Corrosive: pH < 2 or pH > 12.5 = D002- Reactive: capable of a violent reaction (water, air, shock) without

an ignition source = D003- Toxic: Has chemicals present capable of leaching out in amounts

greater than regulatory threshold levels. Must be tested. Some states have additional criteria. = D004 – D043

- Listed: Some chemicals are known to be inherently hazardous and so these are simply listed such that the chemicals, if the sole active ingredient, are considered hazardous wastes when disposed. = F, U and P Listed Wastes

Hazardous or Not?

• OTC and Pharmaceutical Products may contain chemicals that cause the discarded product to be considered acute hazardous waste (counted against the 1 Kg threshold for LQG):

• Nicotine in gum, lozenges and patches, because the FDA required it be listed as the active ingredient, causes products to be acute hazardous wastes.

• Warfarin is another Pharmaceutical that is acute by definition.

P-Listed Waste

• US EPA has delegated states to regulate hazardous waste.

• The programs cannot be less strict, nor inconsistent with Federal Rules

• For example, states that have additional waste codes include:

State Requirements

- Maryland- Maine- Michigan- Minnesota- Missouri- New Hampshire- Oregon

- California- Colorado- Connecticut- Illinois- Indiana- Kentucky- Massachusetts

- Rhode Island- South Carolina- Texas- Utah- Vermont- Washington

• Typically 3 categories of hazardous waste generator:1. < 100 Kg/month = Conditionally Exempt Small Quantity

Generator (CESQG)2. Between 100 Kg/mo and 1000 Kg/mo = Small Quantity

Generator (SQG)3. >1000 Kg/month or >1 Kg/month of acute hazardous wastes

= Large Quantity Generator (SQG)• States may add more categories or use slightly different

names and many do not have the CESQG option.• The more waste you have, the more training and reporting

requirements you have. – and the more fees you pay!

Size Does Matter

Regulatory Requirements for Retail Waste Management

The Rules

• Solid and Hazardous Waste Rules found in Title 40 of the Federal Code of Regulations from section 260 through 370.

• Step 1: Is it a waste?• Step 2: Is it exempt?• Step 3: What are its characteristics?• Step 4: How should it be managed?• Step 5: Planning for Emergencies• Step 6: Sending the waste to an authorized facility• Step 7: Keep Records

• Not all product damaged, expired or taken off the shelf at a store is waste.

• Every retailer should have a process for employees to follow in determining:

1) If a product is no longer sellable at the store, what needs to be done with the product:

a) Salvageb) Donatec) Waste

2) If it is a waste, how is it to be handled, marked and stored.3) How the waste is to be shipped off-site.4) How records (including training) will be maintained.

Have process for making evaluation

Construction Waste

• Construction generates wastes that must be evaluated. Some materials that may have unique management requirements:– Asbestos– Lamps and Ballasts– Electronics– Display items– Lead-based paint

Contractors and Change

• Contractors and Vendors should be agreeing with the retailer on how wastes will be managed– Can manage using retailer’s program ($$-retailer)– Can have vendor program ($$-vendor)

• Transportation of hazardous materials• Training• Administration

• Identify project wastes and have a plan to manage them• Don’t rely on Contractors/Subs to “meet all

environmental laws and regulations.”

1. Once something has been determined to be a waste, it needs to be stored correctly:1) In a marked, compatible, closed container2) In a secure, designated area3) Inspect the container at least weekly (record)

2. People responsible and who handle the waste need to be trained.

3. The retailer needs to plan for emergencies.4. The waste needs to be sent to an authorized treatment,

storage, or disposal facility using an authorized transporter.5. Records and reporting need to be managed.

Basic Requirements

1. Anyone responsible for handling or managing hazardous waste must have training.

2. Training should be completed within 60 days of hire and relevant to the job function.

3. Must include emergency response procedures4. Additional training needed if:

1. Signing hazardous waste manifests2. Responding to hazardous waste spills3. Transporting hazardous waste

Training and Emergency Response

• From the regulations:– Employees must be trained to respond effectively

to emergencies by familiarizing them with emergency procedures, emergency equipment, and emergency systems, including where applicable: • (i) Procedures for using, inspecting, repairing, and

replacing facility emergency and monitoring equipment; Fire extinguisher monthly checks, fire alarm checks, monthly spill kit checks, make sure radios work.

Training (continued)

• (ii) Key parameters for automatic waste feed cut-off systems; Not Applicable• (iii) Communications or alarm -systems; Store Radios,

Phones, Alarms and Verbal• (iv) Response to fires or explosions; Your Store’s Fire

Evacuation Plan• (v) Response to ground-water contamination

incidents; Not Applicable and• (vi) Shutdown of operations. Close Store and

Evacuation Plan

• “The owner or operator must maintain the following documents and records at the facility: – (1) The job title for each position at the facility related

to hazardous waste management, and the name of the employee filling each job;

– (2) A written job description for each position listed under paragraph (d)(1) of this Section. This description may be consistent in its degree of specificity with descriptions for other similar positions in the same company location or bargaining unit, but must include the requisite skill, education, or other qualifications, and duties of facility personnel assigned to each position;

Compliance

Compliance (Continued)

– (3) A written description of the type and amount of both introductory and continuing training that will be given to each person filling a position listed under paragraph (d)(1) of this section;

– (4) Records that document that the training or job experience required under paragraphs (a), (b), and (c) of this section has been given to, and completed by, facility personnel.”

• Retail waste consists of a variety of different products, some of which are not compatible with each other.– Because retail products are smaller containers, they can

be placed into chemical-resistant baggies to keep separate and keep from leaking.

– Place bagged product atop or inside another compatible container to provide secondary containment.

– Have the containers marked with the words, “Hazardous Waste” (note that some states, such as California, Washington and Michigan have additional marking requirements).

Correct Storage

Correct Storage (Continued)

– Have the containers closed and don’t overfill.– Area should have phone nearby with posting of

emergency coordinators.– A fire extinguisher and spill clean-up kit should be

available.– A “no smoking” sign should be posted near the area.– The area should have restricted access.– Inspect the container weekly for evidence of leaks

and corrosion of the containers.

ManagingWaste Products

Universal WasteLamps

• Segregation of products

• Determination

• Storage and containment

• Labeling

• Storage area requirements

• Emergency equipment

• Inspections.

Management

• Products need to be separated according to hazard• Example Options include: • Toxic/Flammable• Oxidizers• Corrosive – Basic• Corrosive – Acid• State-Regulated• Have a way to evaluate!

Segregation and Determinations

With over 100,000

SKUs, what goes

where?

• Wastes must be stored in compatible containers and provided secondary containment if liquids.

• Containers may be either used only in the store, and the waste is separated and profiled for DOT transport by a DOT trained person; or

• Containers may be DOT-approved containers and persons offering to a waste vendor are DOT trained. This option good for limited waste types.

• Provide containment to hold 100% of the largest container.

Storage and containment

Example of Distribution Center

Container Labeling

Containers must be labeled with their contents:• Hazardous Waste• Used Oil • Spent Fluorescent Lamps• Used Electronics• Oily Waste

Some states require additional markings, including waste codes, waste hazard type, and name/address

Date the container became full must also be included on the container.

Container Labeling (cont.)

Containers of hazardous waste should be correctly labeled with their contents. All containers should have a generic description of the contents. Please note that the aerosol cans container should also be grounded.

• “Used Fluorescent Lamps”• “Used Mercury Lamps” (if in Florida)• “Used Batteries” • Thermometers and pesticides may also be labeled

as universal waste, but usually better if managed as hazardous waste.

• Must be dated with first item added (may not store for more than 1 year)

• Lamps must be in a closed container

Universal Waste Management

Storage area requirements

Hazardous Waste Storage areas must have restricted access, access to emergency equipment and means of summoning emergency assistance

Hazardous Waste Storage areas Must also be at least 50 feet from the property boundary

• Employees must be trained in using emergency equipment: fire extinguishers, spill response equipment and personal protective equipment.

• Emergency information should be posted near the phone. • If your store is a Large Quantity Generator, then you must also

prepare and submit a hazardous waste contingency plan.• If your store expects employees to clean up larger hazardous

waste spills, you may need to provide training according to 29 CFR 1910.120.

• Employees are trained in emergency procedures when they start. An annual refresher helps to manage for change.

• This can be a hands-on training.

Emergency Equipment

• Spills and breakage will happen. Clean-up of hazardous materials, fluorescent lamps, and batteries should only be done by people who have been made aware of the potential dangers and will take measures to ensure that the clean-up is performed safely and materials are correctly managed.

• Spills of chemicals can be dangerous and stores should have a emergency contractor number available if the spill is more than a consumer quantity.

Spills and Clean-up

• Broken fluorescent lamps should be cleaned up using dry methods, slowly sweeping the broken glass and debris to avoid dust. Place the broken bulbs into a separate puncture-resistant bag and place with the used lamps for recycling or with toxic hazardous waste.

• Leaking batteries must be placed into a closed, acid-resistant container to prevent spillage.

• Nitrile, latex or rubber gloves should be worn and a dust mask may also be a consideration.

Fluorescent Lamps and Batteries

• Hazardous waste storage areas must be inspected weekly (documented) and specifically look for signs of leaks and corrosion of the containers. Some states require signatures of the person conducting the inspection.

• Corrective action for any leaks or compromise of containers or damage to labels should be taken as soon as possible.

Inspections

Sending the Waste Products to the Right Place

Pre-transport Requirements

EPA ID Number

• Locations that ship a hazardous waste should have an EPA ID number.

• Many states allow CESQGs (<220 pounds HW per month) to be exempt from this

• Be careful! EPA # is by geographic location, so if shipping from a store that has an EPA ID number, it must be identified.

• If no owner/operator control by store, then vendor is responsible!

• You must use authorized hazardous waste transporters and ship to licensed treatment storage and disposal companies.

• New York requires that copies of the receiving facilities ability to accept the hazardous waste be maintained at the generator location (this is usually a copy of their permit).

• ALWAYS have a written contract/agreement with the vendor.

Authorized Vendors

• The DOT requires that specific training be performed for persons shipping hazardous materials, including hazardous waste.

• Hazardous Waste may need to be repackaged for DOT transport. This can be very complicated and technical, so most retailers have their vendors perform this function on their behalf.

Department of Transportation

Hazardous Waste Manifest

• The hazardous waste manifest is the document used to ship hazardous waste

• Universal Wastes, including batteries and fluorescent lamps do not need to be sent using a hazardous waste manifest

• Shipments of Hazardous Waste, Used Oil, Oily Waste, Used Oil Filters, Aerosol Cans and Expired, Unusable, or Damaged Chemicals should be sent using a Hazardous Waste Manifest.

Hazardous Waste Manifest (Cont.)• Item 15: Offeror Certification Statement: “I

hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, and are classified, packaged, marked, and labeled/placarded, and are in all respects in proper condition for transport by highway according to applicable international and national governmental regulations. If export shipment and I am the Primary Exporter, I certify that the contents of this consignment conform to the terms of the attached EPA Acknowledgment of Consent.”

Signing the HW Manifest

–Whomever is preparing the shipment for transport (selecting the container, providing labeling and preparing the shipment papers is the offerer and should be signing. –Many retailers have waste vendors

sign on behalf of the store (authorized in Appendix to 40 CFR 262)

Recordkeeping and Reporting

• Records need to be maintained and available onsite, typically for 3 years from when the record was created.

• Manifests• Reports• Weekly inspection logs• Other records have 3 year sunset requirements:• Training records for 3 years past the departure of the

employee• Waste profiles/determination and land disposal

restriction records for 3 years past when the waste was last shipped

• Can be maintained electronically

Recordkeeping Requirements

• Most states have annual reporting requirements for SQGs and LQGs. Some states have requirements for smaller generators, too.

• LQGs have Biennial Reporting Requirement• Licenses may also be required for some states• Fees are frequently placed upon generators

and paid annually.

Reporting Requirements

Resources for Retailers

• https://wercsmart.kayako.com/Knowledgebase/List/Index/10/regulatory-information

• http://www.epa.gov/retailindustry/• http://

www.retailcompliancecenter.org/Pages/default.aspx

• Wade Miller• wmiller@cc-global.com• 612.326.5253 |O• 952.486.9170 |C

Questions and Follow-up

• 51

Questions and Follow-up

Wade Millerwmiller@cc-global.com612.326.5253 |O952.486.9170 |C

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