If you’ve never heard of a hazardous waste contingency plan or you know your manufacturing facility’s version is woefully out of date, it’s extremely important to get informed and create this document as accurately and thoroughly as possible. It’s a matter of legality, but it’s also about ensuring your facility holds itself to the highest safety standards.
Why Your Manufacturing Facility Needs to Care about Hazardous Waste Contingency Plans
Hazardous Waste Safety
A hazardous waste contingency plan is a document that lists out the exact protocol should any unexpected accident (fire, spill, explosion, etc.) happen with your generated hazardous material.
An accident is just that—an accident. It’s not planned or expected, so your facility needs to be prepared at any minute for an event such as this. A contingency plan can help you accomplish just that.
Should something catastrophic happen and you’re not completely prepared with the steps you and the local authorities need to take, it can mean improper cleanup, slower response time, and an increased risk for everything and everyone involved. Hazardous waste safety is nothing to take lightly, and if you’re not prepared for the worst-case scenario, it can have real-life ramifications. This applies to those hazardous materials getting into the ground, streams, and surrounding environment, but it also can impact the safety of the first responders who arrive for cleanup.
Depending on your facility’s interactions with hazardous waste, you might even need a contingency plan for your facility as well as for hazardous waste transport. A spill or accident while transporting hazardous waste can pose a number of different issues than an on-site incident, and the contingency plans need to reflect those differences.
Environmental Protection Agency (EPA) and Violations
Safety is the most important reason you should implement a thorough, well-thought-out contingency plan. However, there are financial and logistical reasons to consider as well.
If you’re undergoing a hazardous waste audit and you are found to be noncompliant, agencies can point to items such as improperly completed contingency plans to strengthen the case against you as a hazardous waste violator. Lacking a contingency plan or having an incomplete plan is generally considered a smaller violation when compared to egregious noncompliance, such as dumping hazardous waste down the drain or falsifying paperwork (your hazardous waste manifest or bill of lading, for example).
However, not having this contingency plan done—and done correctly—can make you more vulnerable to fines or other punitive actions for noncompliance.
Even today, this is one step that many companies simply overlook or choose to skip, but that’s dangerous for two big reasons: it puts people and the environment at risk in the event of an accident, and it opens up your company to regulatory fines (at the state and federal levels).
If You Generate Hazardous Waste, This Applies to You!
Some manufacturers incorrectly believe they are exempt from this policy because they simply don’t create a lot of hazardous waste. However, that is not the case! Even if you’re not a large quantity generator, you must create this plan and distribute it to the proper authorities. A contingency plan is for any company that produces hazardous materials.
If you’ve never heard of this document before or you don’t know where to start in creating one, contact your local hazardous waste management companies. Reputable, experienced companies should be able to provide you with the resources, information, and guidance you need to get yourself fully compliant. Whether it’s offering templates to facilitate your plan creation or educational insight, waste management companies can tell you everything you need to know when it comes to proper safety protocol.
For more information about why a contingency plan matters to your manufacturing facility, please feel free to reach out to a representative of MCF Environmental Services, an Atlanta waste management company.