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If your Kentucky-based manufacturer produces hazardous materials, it’s crucial that you have (and enforce) a hazardous waste management plan. Why exactly does this document matter, and what do businesses in Kentucky need to be particularly aware of?

01   /   Hazardous Waste Contingency Plans: What Your Kentucky Manufacturer Needs to Know

What Is a Hazardous Waste Contingency Plan?

A contingency plan is a written document that details the specifics of what your manufacturer would do in the event of any spill, accident, or mishap involving your hazardous waste service and facility. Because no one can foresee when an accident is going to happen, it’s vital that this document is in place as soon as possible.

A hazardous waste contingency plan should contain information regarding procedures that are to be followed in the event of potential release or exposure to hazardous waste in the air, soil, or water. It should also contain instructions and contact information for local first responders and local and state emergency teams (40 CFR 265:37).

The contingency plan should also include contact information for all designated emergency coordinators as well as a list of emergency equipment at the facility, along with descriptions and capabilities of that emergency equipment – such as fire extinguishers, spill containment and disinfectant tools or equipment, and necessary personal protection equipment (PPE).

Preparation is the best way to combat the negative effects of an accident, and a contingency plan can help you do just that.

02   /   Hazardous Waste Regulations in Kentucky

Before you can create a contingency plan, you have to know the rules of your state regarding the generation of hazardous waste as well as storage, treatment, and options for hazardous waste disposal in your city and state. 

Kentucky provides easily accessible regulations for hazardous waste collection and disposal. The state follows the guidelines of the federal government in regard to generators of hazardous waste, found in 40 CFR Part 262: Standards Applicable to Generators of Hazardous Waste.

In addition to Federal regulations, you also need to be aware of the rules of the state of Kentucky; primarily the Kentucky Administrative Regulations (KAR) and revised statues (KRS) of Kentucky’s Energy and Environmental Cabinet as they pertain to environmental protection.

Much of what a manufacturer who creates or produces hazardous waste needs to know can be found in 401 KAR rules. For example, the rules related to hazardous waste and permits can be found in the following sources:

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KAR 224.10

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KAR 224.46

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KAR 224.50 through 130

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KAR 224.99

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KAR 304.11 through 030

Revised statues (KRS) relevant to the topic of waste permits include:

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KRS 224.46 through 520 and 224.5-130

The actual rule regarding hazardous waste permit programs is found under 401 KAR 39:090. In a nutshell, it states the existence of regulations that have established hazardous waste permit standards as well as standards for those that store, treat, dispose, or recycle hazardous waste.

Be prepared to wade through a lot of references to other standards. Yes, it’s time consuming and laborious at times, but vital for compliance and safety for your employees, the public, and the environment.

03   /   What do Federal and State Regulations say about Kentucky Hazardous Waste Contingency Planning?

Small and large quantity hazardous waste generators are required by the state of Kentucky to follow requirements for contingency plans and emergency procedures. Such facilities are required to follow these rules:

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Code of Federal Regulations (40 CFR) – §262.16, §262.17, and §262 Subpart M

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401 KAR 39:080 §1(1) Hazardous Waste Handlers.

Follow the regulations for Preparedness and Prevention in regard to hazardous waste generator requirements. The federal guidelines for this category are found in the same sections as the listed CFR above. For the state of Kentucky, follow requirements found in KAR 39:090 §1(1)

Safety Considerations and Your Waste Management Plan

Hazardous waste safety is an important issue. Whether you’re storing or transporting hazardous waste, you need to be ready for a worst-case scenario. Be proactive when it comes to preparedness and prevention. Failure to plan ahead might have serious safety ramifications for everyone involved: the people at your manufacturing facility, the first responders who arrive for cleanup, and the people who come in contact with subsequently contaminated soil or water.

As a generator of hazardous material, you have an obligation to put time, effort, and thought into your waste management plans in order to ensure the greatest level of safety.

Waste Management Plans and Financial Consequences

If your plans are nonexistent, incorrect, outdated, or incomplete, you put your company at risk of facing serious fines. Such issues typically become apparent during a hazardous waste audit of your facility.

While you may believe that lack of a contingency plan is considered a minor infraction, having it on your record during an audit makes you more susceptible to other fines and violations, which in turn can lead to financial ramifications that can be devastating for small to mid-range manufacturers.

Questions? Reach Out to Hazardous Waste Management Companies

With so many safety and financial factors riding on your contingency plan, it’s important to reach out if you feel your Kentucky-based manufacturer needs help. If you’re confused about what this plan should include or have concerns about your compliance, contact MCF Environmental. A reputable hazardous waste service like MCF will help you find and understand the regulations and point you in the right direction if there are serious deficiencies in your current plan.

Give preference to companies that service the Kentucky area, as they should be well versed in the state-level obligations your manufacturer must comply with.

04   /   Special Considerations for Kentucky Manufacturers

Kentucky does not significantly differ from other states in terms of what’s required in a hazardous waste contingency plan. To avoid fines, your facility must be compliant with both federal-level regulations and state-level regulations, so take that into account whenever creating your plan.

Because Kentucky has such a large manufacturing base, a lot of businesses are required to have emergency procedures and contingency plans in place. Don’t take shortcuts. Do it right.

For more information about hazardous waste management and contingency plans and how they affect your Kentucky-based business, feel free to contact a representative of MCF Environmental Services today!

Robert Losurdo

President, COO

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