FOX Environmental, Health & Safety

FOX Environmental, Health & Safety

FOX Environmental, Health & Safety > EHS 701 – Hazardous Waste Management

EHS 701 – Hazardous Waste Management

1.0 Scope

The procedure outlines the handling, storage, and disposal of Hazardous Waste generated during FOX activities and incorporates requirements set forth in the Federal OSHA standards for handling of Hazardous Waste as well as Federal and State standards applicable to generators of Hazardous Waste.

2.0 Definitions

This procedure uses words and phrases that have a defined meaning within the context of this procedure.  These words and phrases are indicated in the body of this procedure with an initial capital letter (i.e. “Hazardous Waste”).  All questions regarding the meaning or usage of a defined term should be referred to the Environmental Health & Safety Department.

3.0 Responsibilities

In addition to required Environmental, Health and Safety (EHS) Program responsibilities discussed in EHS 001, EHS Policy, the responsibilities described below are necessary to ensure the effectiveness of the procedure.

3.1 Department Heads

Department Heads will ensure that supervisors of personnel shipping and/or handling hazardous waste are trained in this Procedure.

3.2 Employees & Contractors

All FOX employees and contractors/vendors working on behalf of Fox:

  • Will not dispose of hazardous waste without having appropriate and documented training as specified in this procedure.
  • Will receive approval prior to disposing of hazardous materials.
  • Immediately notify their EHS representative of concerns or questions about hazardous waste.

3.3 Environmental, Health & Safety Department

The EHS Department will:

  • Develop appropriate procedures for handling, storage and disposal of hazardous waste.
  • Provide technical assistance in the disposal of hazardous waste as requested by Department Heads.
  • Provide professional recommendation of services and facilitate the training of personnel.
  • Perform a periodic review of this procedure to ensure that all requirements are current and meet regulatory requirements.

4.0 Procedure

4.1 Waste Determination and Profiling

Waste determinations (Hazardous vs. Non-Hazardous) will be made by the EHS Department and Department Head and will be based on process and chemical knowledge (e.g. SDS and other research); and further supported through analytical testing as necessary.

A Waste material is hazardous if it possesses the characteristics of either a RCRA Hazardous Waste or Non-RCRA, California Hazardous Waste. Where unique State criteria exist, a separate discussion with the EHS Department is required.

4.2 Labeling

Once the Waste profile designation has been approved, ensure that Containers are properly labeled with “Hazardous Waste” or “Non-Hazardous Waste” labels and stored in the appropriate area.

It is critical that these labels promptly be applied to the Container, once the profile has been completed or when the Waste type is known, whichever comes first. It is extremely important that the labels are completed fully. The label must be clearly visible on the Container. The marking on the label must be permanent and legible. Contact the EHS Department for any questions regarding proper labeling.

4.3 Hazardous Waste Satellite Accumulation Areas

Satellite accumulation is the temporary collection of Hazardous Waste in a Container located at or near the point where the Waste is generated as opposed to a final storage location. Contact the EHS Department for the nearest hazardous waste satellite accumulation area.

4.4 Hazardous Waste Storage Locations

Once the Waste profile designation has been decided upon by the EHS Department and Department Head, the Containers must be properly labeled (see above) and stored in the appropriate Hazardous Waste Storage Location. The Hazardous Waste Storage location meet all Local, State and Federal regulations.

4.5 Inspections

Hazardous waste storage locations will be inspected on a weekly basis.

4.6 Hazardous Waste Handling

The EHS Department is responsible for ensuring that handling of Hazardous Waste is conducted in accordance with  all Local, State and/or Federal requirements. The EHS Department will also ensure that the appropriate Personal Protective Equipment compatible with the material being handled is worn at all times to minimize potential exposure to the Waste.

4.7 Hazardous Waste Container Management

The waste generator is responsible for ensuring that Hazardous Waste Containers are maintained in proper condition in accordance with Local, State and/or Federal requirements. Specific Hazardous Waste Container management requirements include:

  • Maintaining Containers in good condition (structurally sound), with tight fitting lids. Leaking Container contents must be transferred to Containers that are in good condition
  • Ensuring that Containers used for shipping Hazardous Waste are Department of Transportation (DOT) approved packaging in accordance with Title 49 CFR Parts 173, 178 and 179
  • Ensuring that Containers used are made of material that is compatible with the Waste contained or lined with a compatible material
  • Keeping Containers closed unless adding or removing Hazardous Waste
  • Keeping Containers properly labeled (see above).

4.8 Hazardous Waste Manifesting

The EHS Department is responsible for ensuring that every shipment of Hazardous Waste is properly manifested in accordance with requirements of all State, Local and/or Federal . The EHS Manager will prepare a Uniform Hazardous Waste (UHW) Manifest for each shipment of Hazardous Waste transported off-Site for treatment, storage or disposal. The UHW Manifest will include the appropriate EPA ID Number.

A copy of the manifest with a third signature from the disposal facility must be received before the Waste is considered to be at final destination. If a Hazardous Waste manifest is not received back by the EHS Department within 30 days of the original shipment, the EHS Department will contact the transporter and/or the disposal facility to determine location of the manifest and the Hazardous Waste.

If, after 45 days from the date of shipping the Waste, the EHS Department has not received a manifest with the proper signatures back, the EHS Department will submit an exception report to the EPA or applicable State agency, which will consist of: (1) a copy of the manifest for which the Generator does not have confirmation of delivery; and (2) a cover letter which describes the efforts taken to locate the Waste or manifest and the results of those efforts.

4.9 Hazardous Waste Shipping, Disposal and Tracking

The EHS Department has the responsibility of ensuring only transporters that have obtained their EPA Identification Numbers and are licensed to haul Hazardous Waste are used. The EHS Department has the responsibility of ensuring that the Hazardous Waste Containers are only transported by a fully permitted and registered Hazardous Waste hauler. Prior to contracting with a Hazardous Waste hauler, the EHS Department must verify the permits, registrations and licenses of the hauler by independently checking the status of each with the issuing agency. In the event the Hazardous Waste hauler desires to subcontract the work to another Hazardous Waste hauler, the EHS Department must independently verify the permits, registrations and licenses of the subcontractor as well.

The EHS Department will ensure that the Hazardous Waste are transported to the appropriate off-site disposal facility based on the nature of the Hazardous Waste.Only disposal facilities that have obtained their EPA Identification Numbers and are licensed to accept Hazardous Waste are used. Hazardous Waste Containers will only be transported to fully permitted treatment/storage and disposal (TSD) facilities. Prior to subcontracting with a TSD facility, permits, registrations and licenses of the hauler will be verified by independently checking the status of each with the issuing agency.

Once Hazardous Waste storage Containers become full, the EHS Department will make arrangements to have the material removed from the site before the 90-day storage period expires.

4.10 Safety

Employees involved in shipping hazardous materials/dangerous goods (e.g., packaging, preparing paperwork, loading, unloading, and transporting hazardous materials) are required to have documented training prior to shipping activities.

All employees have the responsibility for working in a safe manner, wearing protective equipment where designated and following safety procedures.  All workers, including Department Heads and Supervisors, are responsible for complying with safe and healthful work practices.

Personal Protective Equipment (PPE) shall include but is not limited to safety eye glasses, tyvek coverall, slip-resistant steel-toe shoes, face shield, and gloves

Smoking is prohibited

Review Safety Data Sheets prior to working with unknown chemicals

Convenient and safe walkways must be provided to facilitate housekeeping, maintenance, and waste handling operations

When lifting containers, use the proper precautions, safe lifting techniques and equipment to avoid back injuries

Wash hands after handling of hazardous wastes and prior to eating, drinking, smoking or gum chewing

Know the fastest route from your location to the safety shower, eyewash station, and fire extinguisher

In the event of a spill of a hazardous material, it must be immediately cleaned up in accordance with FOX’s Spill Response procedures.

The handling, storage, and disposal of hazardous waste shall be conducted in a safe manner to protect FOX employees from health and safety hazards associated with hazardous waste management.

4.11 Training

Employees involved in hazardous waste material handling (e.g., preparing manifests, loading, unloading, and transporting hazardous waste) are required to have documented training prior to hazardous waste activities.

4.12 Reporting and Record keeping

4.12.1 Reporting

The EHS Department will ensure that any reports that required for a Generator who ships any Hazardous Waste to a transfer, treatment, storage or disposal (TSD) facility within the United States are submitted.

4.12.2 Record keeping

The EHS Department will ensure that records or reports detailed in this procedure are retained according to Local, State and/or Federal regulations.

5.0 References

Federal Regulations

  • Federal Transportation Regulations in the Code of Federal Regulations, 40 CFR 173.28
  • Federal Hazardous Waste Regulations in the Code of Federal Regulations, 40 CFR 261.7
  • Federal Extremely Hazardous Substances and Planning Thresholds in Code of Federal Regulations, 40 CFR 355, Appendices A and B
  • Federal Acutely Hazardous Wastes in Code of Federal Regulations, 40 CFR 261, Subpart D

State Regulations

  • State Hazardous Waste Regulations in the California Code of Regulations, 22 CCR 66261.7
  • State Extremely Hazardous Wastes in California Code of Regulations, 19 CCR 2729(a); 8 CCR 5189, Appendix A; 22 CCR, Div. 4.5, Chapter 11, Appendix X; and 22 CCR 66261.110 & 66261.113
  • State Acutely Hazardous Wastes in California Code of Regulations, 22 CCR 66261.33(c)