The following is a fictional scenario designed to provide focus on a problem that plays out across industry on a much too frequent basis.
There are 30 drums that have been sitting around the facility for 10 years. Everyone that has intimate knowledge on the what, when and where has moved on. One person “thinks” they know what is in them. A drum is selected randomly and the contents appear to visually match. Based on that limited information, a waste disposal facility is contacted about disposal. A profile form is provided and it is completed based on generator knowledge. The waste is accepted at the disposal facility and a pick-up date is set.
At this point, the following highly regulated decisions have been made. All of them are based on the assumption of what is thought to be in the drums and one visual confirmation;
Packaging, Labeling and Marking
DOT Shipping Description
Waste Disposal Technology
Assignment of EPA Waste Codes
Execution of Uniform Hazardous Waste manifest and associated paperwork
What if the assumption is wrong?!
At the very least, the waste will be considered non-conforming. This will cost the generator a significant amount of money in addition to what has already been agreed upon. Worse case, there could be regulatory issues and potential fines. The waste could also be completely rejected by the disposal facility and sent back to the generator.
The following is a suggested method concerning the same drums that will eliminate the unnecessary liability associated with this scenario.
First of all, the person conducting the following must be properly trained before any activities involving the drums. Since the content of the drums is basically unknown at this point, the assumption should be made that it is hazardous waste. Minimum training should be 40 hour Hazwoper and proper sampling techniques. The individual should also be trained in the proper methods for the field testing that are described below.
1) Proper PPE should be worn. The PPE will vary with the circumstances and a safety professional should be engaged in the PPE selection decision making process.
2) The drums should be inspected for any signs of pressurization and excessive deterioration. If either of these conditions exists, please call a professional waste handling firm to handle the drums.
3) Care should be taken when opening the drum to collect a sample. If the drum is open head without any bungs, please call a professional waste handling firm to handle the drums.
4) When removing the bung, always place your protected hand over it to divert any spray from hitting you if there is pressure built up in the drum.
5) A composite sample should be taken of each drum and placed in a clear jar. It is critical to use a clean sampling device for each drum. The best method for this scenario would be to use a disposable COLIWASA for each sample.
6) Visually check each sample to determine if they appear to be the same material. If some of the containers appear different, then group accordingly.
7) Each sample should then be field tested to establish a higher confidence level that they are the same material. Additionally, the field tests will also assist in raising the confidence level on the identification of the material. An accredited laboratory or a professional hazardous waste management company, should be consulted to determine the appropriate field testing if that knowledge is not available internally. Field testing should be conducted by a knowledgeable person with the appropriate training to conduct the selected tests.
8) The final step is to collect a sample from each group and have an independent laboratory provide confirmation of the contents.
Once the process is complete, then the waste can be profiled and disposed of properly without the possibility of non-conforming waste issues and the potential for regulatory issues.
Keep in mind that the preceding steps are based on having at least some idea of what is in the drums to start with. If the contents of the drums are completely unknown, then a qualified hazardous waste management company should be contacted to perform an identification.