EHS & Waste Management

Cradle To Grave Waste Tracking Requirements for Hazardous Waste Generators

By September 6, 2019 No Comments

The Resource Conservation and Recovery Act (RCRA) is the most comprehensive piece of environmental law that we have on the books today. When the act was created and passed by the US Congress in 1976, it was meant to create a system for controlling hazardous waste from the time it is generated to its final disposal, from “cradle to grave waste tracking.”

While most hazardous waste generators are aware that they have responsibilities under this law, many fail to realize their “complete” cradle to grave waste tracking requirements for compliance with the RCRA regulations for the hazardous waste they generate from its initial generation, its transportation and to its final disposal. This lack of understanding is evidenced by the significant number of fines and penalties levied by government agencies each year upon corporations and organizations within the United States.

The bottom line, if you generate hazardous waste you can and will be held responsible for its improper off-site transportation and disposal.

Short of transporting, storing, treating, and disposing of your hazardous waste yourself, we wanted to look at what a hazardous waste generator can do to minimize their potential liability once the hazardous waste is out of their hands?

This article is designed to provide guidance on questions to ask and information to seek out when choosing your hazardous waste disposal vendor.

What Does Cradle to Grave Waste Tracking Mean?

First things first, “cradle to grave waste tracking” states that a hazardous waste generator is responsible for its waste from initial generation through its ultimate disposal and beyond. Nothing will relinquish a generator of this responsibility. There’s no expiration date or time limit, and hiring a someone else to transport and dispose of your waste does not transfer responsibility from you to them.

That’s why it is vitally important to maintain compliance and ensure you are operating to the regulations. If an incident does occur at any point during your waste’s lifecycle, you can and will be held liable, including costs associated with a response or a cleanup.

Why Is Cradle to Grave Waste Tracking Necessary?

In the mid-twentieth century, solid waste management issues became a matter of great public concern in many areas of the United States because of increasing solid waste generation, shrinking disposal capacity, rising disposal costs, and public opposition to the siting of new disposal facilities.

Several high profile environmental disasters occurred, during the late sixties and seventies including the Cuyahoga River fire and the Love Canal which led to the enactment of many of the federal environmental statutes on the books today, most notably RCRA.

These solid waste management challenges continue today, as many communities are struggling to develop cost-effective, environmentally protective solutions. The growing amount of waste generated has made it increasingly important for solid waste management officials to develop strategies to manage wastes safely and cost effectively.

RCRA sets up a framework for the proper management of hazardous waste. From this authority, EPA established a comprehensive regulatory program to ensure that hazardous waste is managed safely and effectively.

Selecting The Right Hazardous Waste Disposal Company

Companies that generate hazardous waste need to employ the services of a properly licensed and experienced hazardous waste disposal company.

When selecting a hazardous waste disposal company here are some of the key areas to ensure you address:

  • Proper Licensing – EPA, Department of Toxic Substances Control, Department of Transportation, Regulatory Compliance
  • Make sure their employees are properly trained
  • Are the transporter and the Treatment, Storage and Disposal Facility (TSDF) the same company, or are they independent?
  • Will the hazardous waste will be delivered to the TSDF that day.  If not, when?  If there are overnight stops on the road, will the transporter only use secured sites?
  • Ask the initial transporter if any other transporters will be used to deliver the hazardous waste to the TSDF.  Will the hazardous waste be stored in a 10-day transfer site?
  • Will the transporter or TSDF assist in the completion of the uniform hazardous waste manifest? As the Shipper of a hazardous material – which includes a hazardous waste – you are ultimately responsible for the correct completion of the manifest.
  • Does the company have a cradle to grave waste tracking software solution in place that can track all waste movements, combinations and pack downs?
  • Does the Cradle to Grave Waste Tracking Software solution that the company employs use barcode tracking to automate the collection of waste movements?
  • Does the Cradle to Grave Waste Tracking Software solution that the company employs provide customers with a Web Portal so that they can view waste statistics and manifests?

Maintaining compliance with your “cradle to grave waste tracking” requirements cannot be offloaded to your hazardous waste vendor.  You have the ultimate responsibility as the generator to ensure the regulations are followed and maintain the ultimate liability.

IMEC Technologies provides Safety Management Software to increase worker safety and aid compliance. IMEC’s Safety Management Software will manage inspections and audits, provides hazard identificationincident reporting and management of corrective and preventative actions from generation to closure. The Mobile Inspection App allow users to perform inspections and audits, record safety observations and manage corrective actions, anywhere and anytime. The Incident Reporting App allows users to easily and quickly report incidents, hazards and near-misses, these are then sent to the appropriate people for action and are managed to closure.  Web Apps provide features such as, setup, management, scheduling tools, analysis, reporting and dashboards etc with the ability to report incidents to government bodies such as OSHA and RIDDORHazMat T&T is a hazardous waste management software solution designed for Environmental Service Companies and companies who generate a large quantity of hazardous waste. The solution tracks hazardous waste from cradle to grave aiding compliance, providing accurate waste inventory, increasing waste handling efficiency, reducing risk and also helps manage waste costs. For more information visit our website