Hello everyone,
The purpose of this newsletter is to inform our valued clients and business friends of regulatory updates, industry trends, and CES news. We hope you find the newsletter informative, helpful, and a 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.
As we continue to grow, we are dedicated to being proactive and keeping communication as efficient as possible. Please see the updates below and make sure your appropriate team members are aware of the updates. You can always continue to contact your regular account manager as well.
To Schedule a Shipment
please e-mail; Service@certifiedenv.com
or call (262) 800-8520
For Billing Questions
please e-mail; Accounting@certifiedenv.com
or call (262) 800-8520
For Technical Questions
please contact your account manager directly or e-mail; Info@certifiedenv.com
or call (262) 800-8520
Regulatory Review
Proper Waste Container Labeling
One of the initial steps in proper labeling is that waste 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”. 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). In states like Wisconsin a separate label indicating the hazard of the contents is also required. 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. States like Minnesota do not currently require this additional labeling prior to shipment but it might be a prudent practice to adopt.
If you have questions about your state specific labeling requirements, please contact us for a free review of your chemical waste storage program. We can provide insights on best management practices and regulatory requirements for your specific hazardous waste generator status.
Industry Trends
Generator Knowledge
This doesn’t really qualify as a “trend” because it is an industry standard now, but Generator Knowledge doesn’t carry the weight it once used to. Federal and State regulatory agencies have realized it is easier to manage the waste treatment facilities than every generator of industrial waste in the country. This isn’t to say generators of waste won’t be inspected or that their regulatory responsibilities have lessened, but there has been an increased focus on the treatment facilities and particularly with the information provided for waste determinations.
Typical requirements include providing a waste profile, SDS’s, and/or analysis depending on the waste stream. Generator Knowledge on its own will not suffice. It is in all our best interest to ensure the waste we generate is properly identified and managed appropriately. Having the necessary information to support waste determinations helps ensure health, safety, and environmental responsibilities are being met. Any time a waste you generate changes, we should be notified as well.
If you would like to review the information we have on file for your waste streams, please reach out to your account manager to ensure the data we have is current and complete.
CES News
One of the aspects that sets CES apart from our competitors is our ongoing efforts and overall strategy to continuously evaluate where our client’s waste is being shipped, and how the waste is being treated. We do not offer one-size fits-all services and our solutions are customized for each client.
The environmental services industry has struggled since the pandemic and there continue to be long-term challenges. Nationwide labor shortages affect productivity which reduces capacity and creates bottlenecks in storage and transportation services. These challenges have been seen notably in the incineration sector, but they extend beyond to the overall industry. In addition to these challenges the environmental services industry is seeing volatility due to large-scale mergers and acquisitions. Many acquisitions eliminate “redundancies” and key personnel and institutional knowledge are often lost.
To proactively provide the most responsive and competitively priced services, regardless of market conditions, CES has most waste streams our clients generate approved into multiple facilities. This allows us to provide responsive service even if one treatment facility is unavailable for whatever reason. Another benefit of our strategy is to help ensure price stability by having options for where waste is sent.
If you would like to discuss your specific program and where your waste is being sent, and how it is being treated, please contact your account manager and we can provide any information you would like.