Poorly managed hazardous waste poses a serious threat to both human health and the environment at large. In response to a growing need for waste management standards, the Environmental Protection Agency (EPA) created a series of regulations meant to track and regulate the management of hazardous materials. In these regulations, businesses are required to adopt a cradle-to-grave management approach. While this management approach has worked well for deterring improper waste management, the cradle-to-grave approach can create practical problems for organizations looking to manage waste efficiently. It’s essential to understand the cradle-to-grave principle and your company’s responsibilities within that framework, and ERC is here to show you how partnering with a quality waste management company can help mitigate your company’s liability.
What Is the Cradle-to-Grave Approach in Waste Management?
The cradle-to-grave approach in waste management is an imperative of the Resource Conservation and Recovery Act, more commonly known as the RCRA. This law, passed in 1976, established a framework for the proper management of hazardous waste from creation, or “cradle,” to disposal, or “the grave.”
In the cradle-to-grave approach, waste generators are responsible for all hazardous waste they create from the moment it’s generated to the ultimate disposal of that waste. In short, as soon as a company generates waste, that company owns complete responsibility for that waste. The degree of regulation that applies to each generator depends on the amount of waste that a generator produces.
Hazardous waste generators are responsible for the proper handling of waste at every stage of the waste management process, including the following:
- Generation: In cradle-to-grave waste management, the “cradle” refers to the types and amounts of hazardous waste generated by a company. It is the responsibility of the generator to determine if this waste is hazardous and document the waste with proper identification and handling procedures. Companies often start the management process by minimizing their waste output through waste reduction practices or recycling.
- Transportation: Ensuring that waste and waste transportation methods meet the Department of Transportation (DOT) requirements is another responsibility of the waste generator. All waste must be shipped to the DOT standards, meaning that it is properly labeled, stored in appropriate containers and sealed to prevent contaminating the surrounding environment. Your waste transportation provider, similarly, must meet the DOT standards whether they use public roads, highways, rails or waterways.
- Treatment: While some types of wastes can be recycled safely and effectively as they are, others require treatment before disposal to protect soil, groundwater and air resources. Common waste treatment processes include solidification and stabilization. In solidification, liquid and sludge wastes are mixed with absorbents to create solid waste to prevent groundwater contamination. In stabilization, on the other hand, the waste is chemically changed to ensure that it meets requirements for landfill disposal.
- Storage: Waste must occasionally be stored for a period at multiple stages in the waste management process — this could be at the facility, during transportation or during the treatment process. Regardless of where the waste is stored, however, the waste generator is responsible for ensuring that the waste is properly stored to avoid spills and other hazards.
- Disposal: Disposal is the metaphorical “grave” of waste management. Once the waste has been treated and reduced through reuse and recycling opportunities, the waste is dumped into an appropriate landfill or burned for energy. It is the responsibility of the waste generator to ensure that landfills accept their kind and amount of waste and are appropriately licensed to do so.
If any errors should occur at any one of these stages, the cradle-to-grave waste management model means that the generating company is liable for all legal and financial liabilities, as well as the public response. Unfortunately, it is extremely easy to be a hazardous waste generator — simply opening a can of solvent counts as generating hazardous waste. It doesn’t matter how small the quantities are either — while the degree of regulation that applies to your company depends on the amount of waste you produce, improper disposal of any quantity can draw the attention of the EPA.
ERC’s Approach to Waste Management
Ensuring proper handling of hazardous waste can be a full-time job in itself. You must determine the regulations that apply to your company and constantly analyze and update your processes to meet those regulations. On top of it all, you need to ensure that your waste management partners are properly licensed and equipped to handle your company’s waste. Fortunately, ERC is here to help.
ERC specializes in quality waste management, providing our clients with an ongoing relationship in waste management. Our process is cyclical, following a series of basic steps that cover your waste management needs at every level. These steps are detailed in the following sections:
1. Review Your Sustainability Goals
When you partner with ERC, one of the first steps we will assist you with is assessing your waste streams and reviewing your sustainability goals. This is an essential part of setting a waste management plan, which can include some or all of the following steps:
- Assess your waste streams: Every quality operational solution must be based on quality data. By closely analyzing and measuring your waste and waste streams, your business can determine what types and quantities of trash your company produces, how it is produced and what is spent to dispose of it. With this data, your company can more easily determine how to improve sustainability and waste management practices to reduce your liability and maximize your savings. These measurements also serve as a baseline upon which your company can set goals, compare reductions and report successes.
- Assess your processes: How you handle waste internally and externally is essential to appropriate corporate waste disposal. Internally, ERC can help determine if your waste and recycling containers are placed, coded and labeled properly for easy use. We can also look at your internal waste management structure to determine if regulations are being met and internal employees are handling waste streams appropriately. Externally, ERC can help assess your company’s use of waste equipment and services to determine how to maximize efficiency.
- Build waste stream teams: If your company does not already have them, your waste management plan may involve building teams and assigning resources dedicated to waste management and sustainability. An ideal team should include representatives from departments who share responsibility for the management of waste streams.
- Develop improvement plans: Once you have determined where your waste is coming from and how it is being handled, develop strategic action plans to improve your waste management and sustainability. For example, some easy ways to reduce waste production include switching to paperless operations, replacing one-use items with reuseable options, donating useable waste and adopting recycling.
- Set sustainability goals: Using your waste stream data, set realistic goals in the short and long term. These goals for waste minimization and management should be integrated into an achievable waste management plan and reassessed regularly.
- Communicate your goals: Once your goals are set, educate your staff about them and how you plan to achieve them. Communicate goals through internal marketing and training to engage staff and regularly celebrate your company’s successes.
- Regularly check in: To stay on top of your goals, it is essential to measure and report your waste regularly. These check-ins verify that your company is meeting your intended goals and allow for opportunities to update goals and processes in response to successes and failures.
ERC can assist with creating a detailed waste management plan that meets your company’s needs with the goal of improving sustainability and waste disposal costs in your organization.
2. Navigate Government Regulations
ERC will assist your company in navigating the various government regulations that govern your waste management practices. There is a multitude of government agencies that regulate a variety of waste management practices. Just a few of these agencies include the following:
- Environmental Protection Agency (EPA): The EPA regulates the disposal of products with environmental impact. All waste disposal, both hazardous and non-hazardous, is governed by EPA regulations, the most notable of which is the RCRA that sets the cradle-to-grave waste management standard for hazardous waste. Hazardous waste is covered under RCRA Subtitle C, while non-hazardous waste is covered under RCRA Subtitle D.
- Occupational Safety and Health Administration (OSHA): OSHA is the agency responsible for ensuring worker safety and regulates all factors associated with potential employee exposure to hazardous substances, including hazardous waste.
- National Institute of Occupational Safety and Health (NIOSH): Like OSHA, NIOSH regulates issues related to workplace safety and provides guidance pertaining to workplace products that impact human and public health. These regulations also apply to waste in the workplace.
- Drug Enforcement Agency (DEA): The DEA regulates the disposal of controlled substances, which fall into the category of hazardous waste. Facilities like hospitals, medical clinics and veterinary practices often produce hazardous waste that falls into this category and is therefore covered by DEA regulations.
- Department of Transportation (DOT): All companies transport waste from its generation site to its treatment, storage and disposal site. During this transportation process, the waste falls under the jurisdiction of the DOT, which regulates how waste must be stored and handled during transportation.
- Federal Aviation Administration (FAA): In some rare cases, waste may be transported via air. In these cases, the FAA regulates appropriate transportation practices.
- Nuclear Regulatory Commission (NRC): Power plants and medical facilities that provide nuclear therapies likely produce nuclear waste. This nuclear waste is subject to regulation by the NRC.
Based on the types of waste your company produces and the most appropriate waste disposal methods, ERC can determine which agencies and regulations your company needs to work with and how you can meet their standards. Armed with this information, your company can properly process your residual and hazardous waste streams without the fear of legal and financial repercussions.
3. Build a Partnership With a Waste Management Company
When you partner with ERC, you partner with a company that is dedicated to supporting your organization’s ever-changing sustainability demands. Building this kind of partnership offers numerous benefits for your organization, including the following:
- Detailed understanding of your business: Waste disposal is a complex issue, unique to every business due to the state and federal laws that apply to them. ERC takes the time to understand your business and its needs, learning your waste streams so that all guidelines and regulations are met from start to finish. This way, you can rest easy knowing that your waste removal is in the right hands.
- Leveraged experience: Partnering with a waste management company means that you can benefit from their experience in the field. Your company benefits from this experience through efficient service and comprehensive training and insurance, and you can discuss your processes and waste management options with your partner to determine ways to improve efficiency and sustainability.
- Customized services: Building a partnership with a waste management company can help you customize their services to meet your needs. Your waste management company should know that businesses are highly diverse and that one-size-fits-all approaches simply don’t work. ERC understands this, offering customized waste management programs that are designed to fit your business operations. This way, you’re not spending money on services you don’t need, and you can change your program to meet your ever-changing business needs.
- Attention to your needs: When you need a specialized service or an emergency collection, many waste collection companies charge high fees or direct you to other services. You need a waste management company that meets your needs from day one. ERC can help with a full-service facility that can handle your needs, no matter how drastically they change.
- Tailored prices: Waste management needs constantly change, and your waste management company must change with them. Many waste management companies charge base rates that cover services your company doesn’t need, or charge fees for services you need regularly. By partnering with a waste management company like ERC, you can discuss your price and tailor your package to meet your needs without the hassle or ambiguity. Your waste management partner can cover everything you need in an all-inclusive bill so your costs are predictable from month to month.
With these service benefits, ERC can ensure that your business’ goals are met, including cost, compliance and sustainability goals.
4. Leverage Our In-House Capabilities and Distinguished Network of Partners
ERC and its facilities can handle all waste streams from start to finish with our on-site capabilities and our distinguished network of industry partners. In fact, many waste disposal companies in our region choose to hire ERC to dispose of their waste because we have everything they need in-house. ERC’s capabilities include the following:
- Versatility: As a full-service waste management company, ERC provides comprehensive solutions that meet your company’s needs. We can handle a wide range of residual and hazardous waste types. For any waste we can’t handle in-house, we have experienced partner services to take care of it. Because of this range of services, we offer waste disposal services for a broad range of industries, including the pharmaceutical industry, manufacturing industry, construction industry and even the petrochemical and fuel industries.
- Experience: With over 30 years in the industry, ERC has the experience customers look for in waste management. Our decades of experience and our status as one of the largest industrial waste processors in the Mid-Atlantic region gives us insight into the waste management industry and how our customers can leverage their resources most effectively.
- Compliance: Compliance with government regulations is one of ERC’s core values. Our team members work hard to ensure that waste is processed according to all applicable local, state and federal regulations. We also verify that our collectors are trained and insured at every level, protecting your waste from start to finish.
- Sustainability: At ERC, our services are centered around sustainability. Improving and protecting the environment is another of our core values, and our team can help you achieve improved sustainability using our resources.
- Processing: At ERC, we have the teams and technology to deliver elite waste processing solutions to meet the needs of any industry. Between our state-of-the-art waste processing lab, our industrial wastewater treatment facility and our processing building, we can create customized treatment solutions for any type of waste.
- Disposal: ERC owns and operates a fully compliant disposal site of its own, so you don’t have to contact anyone else for your disposal needs.
On top of it all, ERC focuses on personalized customer service at every level. We meet with our customers, taking the time to understand the needs and desires of your business. We then leverage our in-house capabilities, experienced staff and network of partners to find you the solutions that maximize your sustainability and cost savings.
5. Measure Progress and Streamline Your Systems
As a last ongoing step in ERC’s system, we help measure your progress in your waste management journey, then use that information to continue streamlining your systems and refining your mission. Starting with the data collected when we assessed your processes and set your company’s waste management and sustainability goals, we will help you collect data on your waste for comparison and analyze that data to gain valuable information.
The key to measuring your progress is to identify opportunities for improvement. Some ways that progress assessment can improve your business include:
Enhancing sustainability: If your business is falling short of its sustainability goals, this data can pinpoint the source and use that information to create new sustainability plans that target problem areas.
Identifying inefficiencies: Some processes that are efficient in the beginning may become less efficient as businesses and resources change. Monitoring your waste analytics can help pinpoint small changes in your process that could make a big impact, such as changing transportation and storage methods. It can also identify resources that are being wasted. For example, your company may have started out on a contract using a 40-foot dumpster, but switching to paperless may have reduced your waste so that a 20-foot dumpster is sufficient.
Reducing costs: By identifying areas of improvement, your business can slowly become more efficient, cutting costs and maximizing resources so you can minimize costs while maintaining compliance at every level.
The ultimate goal for ERC is to make your waste management as efficient as possible, allowing you to trust us with waste disposal so your company can focus on your most essential business functions.
More Than a Cradle-to-Grave Waste Management Process
With ERC, waste management is more than a cradle-to-grave process. Instead of a linear process, ERC offers an ongoing relationship that takes your unique needs into account with every cycle. When we help you finish one waste management project, we’ll then help with the next one. With our wide range of services and our attention to your needs, you can trust ERC and look forward to waste management that takes it to the next level. We got this.
If you’re looking for sustainable waste management solutions in Pennsylvania or Maryland, ERC is here to help. Let us work with your company to discover ways to improve your waste management and reach your sustainability goals. To learn more about ERC, cradle-to-grave management or our cyclical waste management process, contact ERC to schedule an on-site waste assessment.