Hazardous Waste Reduction Plan Checklist
The following information must be submitted as part of a Hazardous Waste Reduction Plan:
(Detailed guidance for each item is provided in the Guidance Document for Hazardous Waste Reduction Plans, Annual Reports and Biennial Updates.)
- Identify (at the point of generation), the amount and type of all acute hazardous wastes generated by waste stream.
- Identify (at the point of generation), the amount and type of all non-acute hazardous wastes (aqueous and non-aqueous), whose annual generation by waste stream is greater than five tons. Identify at least 90% of all non-acute hazardous waste (aqueous and non-aqueous), generated at the facility. A description of each source of hazardous waste identified, and the waste management method for each of these waste streams.
- Submit block diagrams of the process(es) generating the waste. Include at a minimum:
a) raw material inputs;
b) major process steps and equipment; and
c) product and waste outputs
- Provide an activity/production index for each identified waste stream. The activity/production index is a measure of changes in economic and other factors that affected the quantity of hazardous waste generated in a specific year, compared to the previous year. If an index cannot be developed to provide meaningful information on waste reduction, then provide some other measurement technique or a demonstration why such calculation cannot be provided.
The index facilitates the quantification of waste reduction efforts by distinguishing inter-year quantity changes that resulted from waste reduction activity from those that are attributable to economic or other factors. Examples of index calculations follow:
Example 1: If the firm manufactures tools using a process that generated a hazardous waste, the activity/production index would indicate the change in the number of tools produced in 1995 compared to 1994. 1,200 tools were produced in 1995, and 1,000 tools were produced in 1994. The activity/production index equals 1,200 divided by 1,000 (1995 production divided by 1994 production) = 1.2
Example 2: If a firm that manufactures stainless steel food containers is losing market share to competitors making plastic containers, its production might have declined between 1994 and 1995. 88,000 containers were produced in 1995, and 110,000 containers were produced in 1994. The activity/production index equals 88,000 divided by 110,000 (1995 production divided by 1994 production) = 0.8
Example 3: If a firm is a dry cleaner that cleaned 2,200 garments in 1995 and 2,000 garments in 1994, the activity/production index would indicate the change in the number of garments cleaned. The activity/production index equals 2,200 divided by 2,000 (1995 production divided by 1994 production) = 1.1
- Submit the costs for managing each waste stream. For each waste stream, submit an evaluation to determine the technical feasibility of:
- substitution of non-toxic or less toxic inputs
- reformulation or redesign of end products to eliminate production inputs
- modification or redesign of production processes/equipment
- changes in materials usage, handling and storage practices
- use of closed-loop reclamation, reuse or recycling wastes directly back into the production process
- use of on-site or off-site recycling technologies.
- Submit a return on investment number for each technically feasible waste management option identified above.
- Provide a list of technically feasible and economically practicable waste reduction measures as identified above.
- Submit a description of your corporation or facility Waste Reduction Policy. This should include:
- specific short-term and long-term goals and objectives for hazardous waste volume and/or toxicity reduction
- a statement of top-level management commitment to waste minimization
- methods used to accomplish top-level management support, e.g., reward and recognition program
- designation of a waste minimization department or team responsible for implementing the hazardous waste reduction plan
- a statement of commitment to implement recommendations resulting from waste minimization assessments.
- Provide: a schedule for implementing technically feasible and economically practicable waste reduction actions; a description of the method to be used to measure waste reduction over time; a description of your employee hazardous waste reduction training program; an estimate of the anticipated hazardous waste reduction (by waste stream) expected from implementing the hazardous waste reduction plan; an estimate of the extent of transference of hazardous waste to other media (air, water etc.) expected from implementing the hazardous waste reduction plan. If transference occurs, is there an associated overall environmental benefit?
- Submit completed Hazardous Waste Generation Summary - Table 1
(View sample of Table 1 - Download a blank copy of Table 1(PDF, 9.3KB))
- Submit completed Hazardous Waste Reduction Program Summary - Table 2
(View sample of Table 2 - Download a blank copy of Table 2(PDF, 4.9KB))