Federal hazardous waste regulations changes in 2017 and 2019 under the Resource Conservation and Recovery Act (RCRA) have increased regulatory oversight and scrutiny of “non-industrial” business sectors such as hospitals; healthcare-related businesses like pharmacies and laboratories; retailers; and academic institutions. These sectors and their environmental impact have been historically overlooked when discussing RCRA compliance, but accompanying increased regulatory attention is an increase in the environmental risks these business sectors are facing. This translates to new challenges in unfamiliar territory for many businesses.
Since nearly every facility within these sectors is a hazardous waste generator, business and facility leaders must understand the complex environmental compliance requirements their business and properties are subject to. Understanding these requirements while implementing a compliant waste management system is a mammoth task given the hundreds, if not thousands, of wastes and waste streams generated by these entities annually. These facilities, which for many companies are spread across the country, are also subject to state and sometimes local hazardous waste regulations which are often more stringent than federal RCRA rules.
合规的关键流程
Before even approaching the meat and bones of compliance, there are two major initial components to address. Step number 1A in minimizing the environmental, legal, financial, and other inherent risks in being a hazardous waste generator is knowing and applying regulations and the corresponding hazardous waste program compliance requirements. Step number 1B is completing an accurate and up-to-date waste inventory to determine the actual hazardous waste compliance requirements that apply to your operations. From this point on, the hazardous waste notification; segregation; collection; storage; training; spill response; manifesting; disposal; and reporting (if required) practices and procedures are developed and implemented so that your facility can adhere to your specific regulatory compliance requirements.
组织缺陷和全身盲目点
鉴于RCRA法规的复杂性和这些非工业部门的性质，医院的商业领袖，医疗保健，教育和零售业可能缺乏适当符合与RCRA相关的监管合规性要求的内部机构经验。不幸的是，系统性或急性合规问题可能只会在政府机构合规检查或废物或化学管理事件中发现。当发生这些方案中的任何一种时，通常发现任何单个人或业务部门都对RCRA危险废物计划负责。
Practical Compliance Steps for a Zero Violation Program
To avoid situations like this — which sometimes can trigger significant environmental risks such as unwelcome publicity — there are practical compliance assessment steps (at either facility, regional or company-wide levels) businesses in these sectors can proactively take to minimize the impacts of non-compliance with RCRA hazardous waste regulations.
What do these steps look like? Join environmental consultantDarrell阿曼on September 24th关于工业和非工业部门综合计划管理方法的网络研讨会。Darrell在环境，健康和安全（EH＆S）领域拥有超过30年的咨询，计划开发和风险管理经验，并且很兴奋地分享他在这个现场交互式网络研讨会中的见解。