The purpose of this newsletter is to inform our valued clients and business friends of our environmental services regulatory review including updates, industry trends, and CES news. We hope you find this to be an informative, helpful, and worthwhile read.
Plan for Success
The 4th quarter of every year is a busy time in the environmental services industry. Many clients remove obsolete chemicals and wastes at the end of the year to have those costs on this year’s books and to avoid possible price increases in the following year. When you factor in projects needing to be completed before the snow hits, holidays, employee vacations, and overall increased year-end demand, the 4th quarter gets busy quickly. If CES can assist you with any of your environmental program needs, please let us know.
Environmental Services Regulatory Review
Proper Hazardous Waste Container Labeling
One of the initial steps in proper waste labeling is that the containers need to be labeled as soon as waste is placed in them. The term “containers” includes small items such as pails up to bulk storage tanks and more. It is common sense that some identification be on the container so incompatible materials are not placed inside, among other environmental, health, and safety considerations. What surprises some people is the extent the labeling needs to be to meet regulatory requirements.
If the waste is hazardous, a label needs to be on the container stating it contains “Hazardous Waste”. But simply labeling the container as hazardous waste does not meet the regulatory requirements. The label must also include the accumulation start date (unless it is from satellite accumulation in which the container is labeled when it is full) and an indication of the hazard of the contents. This means a label needs to be on the container identifying if it is ignitable, corrosive, toxic, and/or reactive. The additional labeling can be achieved with a DOT hazard class diamond, NFPA labels, and/or OSHA HazCom pictogram.
If you have questions about your specific labeling requirements, please contact us for a free review of your chemical waste disposal and storage program. We can provide insights on best management practices and regulatory requirements for your specific hazardous waste generator status.
Environmental Services Industry Trends
The environmental services industry, on a national level, is still struggling like many industries are. The environmental services industry has not been immune to labor shortages, transportation challenges, and capacity issues at several waste processing facilities. Certain segments of the industry are performing better than others with incineration being challenged the most. These challenges will most likely persist for the foreseeable future as they are not quickly or easily resolved. Building new waste processing facilities takes a long time and requires a significant amount of capital. Hiring qualified employees to help transport chemical wastes and process the wastes has been challenging as well.
We have been asked many times how we have continued to aggressively grow in these challenging times. The simple answer is we have continued to reinvest in our business to expand our services and resources to meet our client’s needs. We have found tremendous success in this approach and we are able to offer responsive services and economical pricing some of our larger competitors cannot. An example of this is many vendors have stopped receiving wastes destined for incineration. We routinely ship wastes requiring incineration including pharmaceutical disposal, pesticides/herbicides, reactive chemicals, isocyanates, and more.
To conclude our environmental services regulatory review, did you know we routinely buy and sell unwanted chemicals? We help find beneficial uses for unwanted chemistry that clients no longer need. Recently, we have provided hand sanitizer recycling for large volumes of hand sanitizers and we have been able to manage them as products and not as hazardous wastes. If you have unwanted virgin chemicals please contact your account manager and they will discuss what options are available for your specific needs.