There is a stubbornly persistent belief among some waste generators in the industry that all Environmental Services (ES) companies are created equally. This flawed mindset leads to a commoditized view of the world that is driven by cost and cost alone when it comes to vendor selection for remediation, spill response, or hazardous and non-haz waste disposal. All the training, safety, and compliance programs enacted and enforced by a reputable firm like SR&R to manage risk for our clients is occasionally disregarded in favor of simple cost savings. However as many recent events have shown, this can lead to significant (even catastrophic) liability for a waste generator when the waste is mismanaged, or worse, disposed of illegally.
While this type of issue is usually blamed on smaller “one guy and a truck” operators, one of the largest environmental companies in the industry with hundreds of employees and multiple locations across the Southeast was recently busted illegally discharging heavy metal laden leachate into a creek by the tanker load. And unfortunately for the generator, this contractor’s actions have now potentially created tremendous liability for both parties. This stems from the fact that no matter the final disposition of the waste, the liability is retained by the generator “from cradle to grave.” So, if you pay someone to handle your waste stream and they go dump it in the woods somewhere illegally, you’re afforded no protection when it comes time to dig it back up, dispose of it correctly, and remediate the site. Countless generators (both LQG and SQG) have been unwittingly added as defendants in legal action created by the actions of unethical contractors. This is why savvy generators understand that when it comes to waste disposal contractor selection, there’s more to the equation than just price.
So how does a generator control the risks that are inherent in waste management? The first and most obvious thing to check when choosing a contractor is their certificate of insurance. Check their limits, expiration date, types of coverage, and insurance company rating. Generally, most contractors will have some form of insurance but does it cover the transportation of your waste off-site? Are they a licensed or permitted hauler for your type of waste? If they’re sending the waste to a 3rd-party Treatment Storage and Disposal Facility (TSDF), is that final disposal facility permitted and up to the standards of your organization? If the contractor operates their own treatment facility like SR&R does, is it permitted for the waste they’re receiving for disposal? What is the compliance history of the facility? Always ask for a site audit so you can see the place for yourself. Are tanks in secondary containment, do they have SPCC plans in place if necessary, and a spill contractor on retainer or on-site? And finally, what does their waste disposal program look like in terms of profiling, sampling, and manifesting? Can they provide profiles and manifests showing where the waste ends up? Any reputable waste contractor will practically drown a generator in paperwork showing when, how, and where the waste was handled. This “paper trail” is the insurance that helps generators sleep at night knowing that their waste was sent to a permitted facility and not dumped in a stream somewhere. It’s also one of the first things a regulator from the state or EPA will look for if the generator gets inspected or audited. Chances are that if the paperwork isn’t in order, neither is the waste.
At SR&R, we have built a strong reputation around the mantra “bigger isn’t better; better is better.” That’s why our compliance program has earned us the trust of clients like Duke Energy, GE, ADM, and Koch Industries. We are a licensed Hazardous Waste Transporter and our insurance coverage far exceeds the industry average. We are also one of the few companies who can provide a turnkey approach to your specialty waste streams. We’re there for you at every step of the way:
- Waste Identification and Profiling for Disposal
- Waste Transportation
- Hazardous and Non-Hazardous Waste Disposal
All waste streams are rigorously profiled and analyzed prior to acceptance for disposal. Once the waste is in our custody, sampling and further analysis is performed to ensure compliance with the established profile. And when the waste is finally disposed of, a complete package including signed and numbered disposal manifests is submitted for your records. All of this translates into peace of mind knowing that your project is done right and in accordance with local, state, and Federal regulations. Don’t trust just anybody with the transportation and disposal of your waste. And don’t risk having your facility’s name in the paper as a party to illegal disposal. Trust SR&R and make sure it’s done right. Please contact us today for more information on how SR&R can help streamline your special waste needs.