Choosing a vendor
Although you may rely on other companies to haul away and dispose of your waste, you are ultimately responsible for the waste from "cradle to grave." Choose your vendors carefully, considering reliability as well as cost.
What kind of vendor do you need?
The best vendor for you isn't necessarily the least expensive one. Don't trade short-term cost savings for long term liabilities.
Look for vendors whose services match your needs. Do you have just one waste, like antifreeze or spent photo fixer? If so, it may be smart to find a vendor who specializes in recycling that particular waste. Look up your waste in the Waste Directory.
If your shop or business produces a number of hazardous wastes, you may want to hire a more general hazardous waste vendor. These are listed under Hazardous Waste Disposal in the Waste Directory. These vendors, or brokers, can handle a variety of wastes. Their services typically include identifying the wastes (profiling and testing them), transporting wastes to recycling and disposal sites, preparing manifests and other paperwork, and in some cases, actually disposing of the waste.
Although regulations don't require small quantity generators to obtain a RCRA site identification number, many waste vendors require SQGs to obtain an identification number from the Department of Ecology. This involves submitting a notification form (Form 2). Call Ecology at (425) 649-7000 to get a form.
The best vendor for you isn't necessarily the least expensive one. Don't trade short-term cost savings for long-term liabilities. If more than one vendor handles your waste (for example, if one vendor transports it and another recycles it), make sure each one is reputable.
How to determine if a vendor follows legal requirements.
It's a good idea to conduct yearly environmental audits of vendors handling your hazardous waste. As can happen with any business, a reliable environmental vendor can become unreliable. A simple method is to check Ecology's list of active hazardous waste and used oil facilities. That Web site has instructions for viewing the recent compliance history of state-permitted sites. Or for Washington State firms, contact the Records Division of the Department of Ecology at PO Box 47658, Olympia, WA 98504-7658. Request a copy of the vendor's most recent inspection report as allowed under Washington's Public Disclosure Law. The inspection reports tell whether and what compliance violations may have taken place. You can then fully determine your confidence level as to whether "Cradle to Grave" will be met.
How to find a vendor
When you interview a vendor, ask some questions:
- Can the vendor provide the names and phone numbers of current customers (similar to you) as references?
Check with the references to see how satisfied they are with the company's services. Be sure the company has experience with wastes like yours.
- Does the vendor have adequate insurance?
In addition to general commercial liability insurance, vendors should have coverage for pollution caused by spills while hauling waste.
- Where do your wastes go?
Some vendors are waste brokers: they haul waste from your shop to another treatment, storage, disposal, or recycling (TSDR) facility. Other vendors haul waste to their own treatment, storage and disposal facility. Hazardous wastes can be reprocessed and recycled (and sometimes resold), blended into fuels, incinerated or buried in landfills. Recycling wastes or using them as fuel substitutes is preferable to putting them in landfills.
- What documentation and other paperwork are provided?
Vendors may help you prepare manifests and other papers, but because you sign them, you need to be sure they are accurate. Manifests and receipts track your waste from your site, to the hauler, to the receiving facility. Get copies of the manifest and receipts from the hauler and the TSDR facility and keep these at least five years. Better yet, keep them forever. If you are a small quantity generator, you do not need to manifest the waste you ship. However, a manifest provides you with added protection. (Note: Small quantity generators do not need a RCRA site identification number to use a manifest. Just write "SQG" or "CESQG" on the manifest form.) Vendors may also help you with other paperwork, including the Department of Ecology's annual generator report.
- How much will the services cost?
The total cost of handling your waste can include a number of fees: a waste profile or lab fee, a hauling charge (sometimes called a stop charge), a disposal fee and a drum replacement charge. Ask vendors what they charge for each of the above items. Ask which charges are one-time and which are ongoing. Find out if there are any other fees you must pay.
- Does the vendor charge more for the following contaminants?
- Chlorinated solvents? Most vendors charge more if hazardous liquids contain chlorinated solvents. Small amounts of these solvents can contaminate an entire drum or tank of other types of waste. To avoid contamination, know your chemicals. Look for the syllable "chloro-" in the list of ingredients on the container or on the material safety data sheet and avoid mixing those solvents with other wastes.
- Water? Fluids containing large concentrations of water (usually more than 10 percent) cannot be burned for fuel recovery. The more water, the higher the cost for disposal.
- Heavy metals? While the presence of metals may not affect disposal costs, additional lab testing may be required. Ask your vendor.
- What recycling credits are provided?
If your waste is recycled into usable product, you can get a credit against the total amount of waste you produced that year. You can use the credit when filing reports with the Department of Ecology. This is especially important to businesses that produce more than 2,640 pounds a year (about 5-6 drums) and have to write a pollution prevention plan. Recycling credits can reduce your fees and possibly drop you below the pollution prevention planning threshold.