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By: Dave Carey
DEALING WITH OUT OF DATE/OFF SPEC PRODUCTS
Spring is just around the corner and is a great time to complete clean-ups both at home as well as work. So when the warehouse is cleaned up and a few old containers are found, how should these materials be handled? Waste materials are regulated at both the state and federal level and the rules for disposal must be complied with. By doing a little leg work, a generator of waste can keep costs to a minimum as well as comply with regulations regarding proper disposal.
The first step is to identify what the material is. If labels are present, great. If not, is the manufacturer known? Is there a batch number on the container? Can the container be opened and contents identified? The key here is to gather as much information as possible so the appropriate disposal facility can be retained. An unmarked pail may contain a water-based curing product, a solvent-base sealer, or a blend of the two. These types of materials will likely go to different disposal facilities.
Once identified, request a safety data sheet from the manufacturer. If the container is badly rusted, bulging, or leaking, it should be repackaged or overpacked. Waste haulers as well as disposal facilities will not accept damaged or leaking containers. If containers are partially full, combine like materials together. Most disposal facilities charge per container, so it is best to fill containers up as much as possible. Mark containers permanently to identify contents.
Once materials are properly identified and packaged, it’s time to locate a disposal facility. The key to keeping costs at a minimum is to match the waste to the disposal site. If waste is shipped to a facility and then transshipped to another facility for disposal, there will be additional transportation and handling charges. Understand how the waste will be handled and if it will be comingled with other generators waste.
A manifest will be completed when the waste is shipped. An original copy will be left with the generator and a return signed copy will be provided by the disposal site once the waste is received. If a return copy is not received within 10 days, it’s time to call the disposal facility to make sure the waste was received. Manifests are required to be kept on-file for three years. I would recommend keeping them forever. These records document that the waste was properly disposed of.
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W. R. MEADOWS’ VP Dave Carey gives an in-depth look at VOC rules and regulations. Dave has over 30 years in the industry, and oversees all of the legal requirements facing W. R. MEADOWS. For more information about products and standards, click here: https://www.wrmeadows.com/standards-approvals
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