In our February 27th blog, my colleague, Matt Schroeder, wrote an excellent article about the 15 Essential, Environmental Considerations for Site Closure Activity. Number three on Matt’s list was “Conduct a hazardous materials survey and removal.” Unlike hazardous waste as defined under the Resource Conservation and Recovery Act (RCRA), a hazardous material is not necessarily associated with chemical handing and “industrial” processes.
Typically, a RCRA hazardous waste is more clearly defined (e.g. characteristically hazardous or listed waste). Hazardous materials, on the other hand, are not always so “clear cut.”
Hazardous Materials
The Institute of Hazardous Materials Management (IHMM) states, “Hazardous materials are defined and regulated in the United States primarily by laws and regulations administered by the U.S. Environmental Protection Agency (EPA), the U.S. Occupational Safety and Health Administration (OSHA), the U.S. Department of Transportation (DOT), and the U.S. Nuclear Regulatory Commission (NRC). Each has its own definition of a ‘hazardous material.’”
So, identifying hazardous materials associated with your facility will, likely, require a bit of up-front planning before you begin renovation or demolition. However, this planning is critical if you are to avoid improper handling, exposure, or disposal of hazardous materials.
Here are some examples of potential hazardous materials sources, general use, and the chemicals of concern:
You should know what hazardous materials you have at your site, especially if you are closing or decommissioning your manufacturing plant
Even though you may have never generated any hazardous waste at your facility and never had to obtain any permits or develop any plans for handing hazardous waste, when it’s time for demolition or renovation, you will likely need to consider hazardous materials.
If you have questions about hazardous materials or hazardous waste, our Senior Vice President, Jeffrey Bolin, is a long-standing member of IHMM and is a Certified Hazardous Materials Manager (CHMM). You can reach Jeff (jbolin@dragun.com) at 248-932-0228, Ext 125.
Also see our Environmental Compliance Tips page, which includes monthly compliance tips/reminders.
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