BC’s Compliance and Permitting team often sees how challenging it is for clients to track the types and amounts of waste they generate. Without diligent recordkeeping, facilities may miss the documentation associated with the types of wastes generated and the appropriate disposal methods. The lack of tracking can also mean missing a change in hazardous waste generator status and additional regulatory requirements. These misses can lead to noncompliance with state and federal regulations, including the Resource Conservation and Recovery Act (RCRA).
Setting up systems and tools for waste inventory tracking, as well as documenting waste determination, are key actions to support a pathway to compliance. Two recent developments underscore the importance of due diligence.
Hazardous waste violations
This recent settlement in Alaska highlights the importance of being familiar with waste management requirements and the waste management practices at your facility.
Under RCRA, hazardous waste treatment, storage, and disposal facilities (TSDFs) must be inspected at least once every two years, which may include a formal visit to the facility, a review of records, taking of samples, and observation of operations.
In other environmental updates, we highlight the following in our Compliance News:
Proposed PCE ban
Last month, the EPA proposed a rule under the Toxic Substances Control Act (TSCA) that would ban all consumer use of perchloroethylene (PCE) and, for industrial/commercial use, implement a workplace chemical protection program with a strict inhalation exposure limit and requirements.
Climate change impact on insurance coverage
As more frequent and severe weather events attributed to climate change occur, insurance companies, such as State Farm, are beginning to decline coverage for homeowners and businesses in high risk areas.