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    What C-stores May Not Know About Hazardous Waste

    New era of EPA governance is on the horizon.

    By Mike Rozembajgier , Stericycle Environmental Solutions

    Ask most owners of small- and medium-sized businesses (SMBs) how much hazardous waste their company produces, and you may get a quizzical look. The same can be said about operators of local, regional and national convenience stores, for whom insight into their hazardous waste volume and disposal may not be at the top of the priority list.

    For many SMBs, the complex rules and enforcement policies of the Environmental Protection Agency (EPA) have combined to make hazardous waste compliance a source of confusion and uncertainty.

    A new rule change being considered by the EPA seeks to provide clarity, updating hazardous waste generator regulations for easier understanding, compliance and flexibility. The new rule, if implemented, will alter the “generator status” — or classification of a business as it relates to the hazardous waste it produces.

    Many convenience store retailers may see their generator status change, impacting the way they are expected to handle, record and dispose of their hazardous waste.

    Hazardous Waste in Retail

    Hazardous waste in convenience stores can consist of everyday items most consumers wouldn’t think of as hazardous — products such as batteries, light bulbs, nail polish and other personal care products, for instance. Additional items such as aerosols, mouthwash, medicine, dishwasher detergent, flammable liquids, car care products, insecticides and nicotine patches are also considered hazardous waste.

    Regardless of generator status, convenience store retailers must operate their businesses in ways that protect their consumers and the environment. Retailers are tasked with ensuring that each location has the proper equipment for waste storage, processing and removal, along with the ability to document compliance for various agencies.

    Hazardous waste management is a challenging process that requires expertise and accountability. The consequences of failing to be compliant, including aggressive fines and lasting brand damage, are far too real to ignore.

    To ensure hazardous waste compliance, convenience store retailers can leverage the expertise of hazardous waste technicians. Hazmat-trained professionals can offer customized waste containment/segregation programs to address every customer need, from categorization to transportation.

    A typical hazardous waste program may entail:

    • Management and monitoring of employees for hazardous waste compliance
    • Delivery of hazardous waste store supplies, and store setup
    • Safe and compliant waste segregation and containment
    • Compliance documentation designed to satisfy reporting requirements and minimize penalties
    • Safe, compliant hazardous waste transportation
    • Advanced, near-real-time tracking of all compliance data

    Hazardous waste programs such as these may have greater significance with the expected changes coming from EPA in 2016. The rule change provides convenience retailers with an opportunity to revisit their hazardous waste management and prepare to save costs, create efficiencies and maintain compliance with hazardous waste management. 

    30 Years in the Making

    The anticipated rule changes are the first in three decades, when the EPA authored its current rule governing how hazardous waste is classified, recorded, disposed of and reported. Originally designed for the manufacturing industry, the rule eventually stretched to include retailers and other businesses. The uniform expansion of the rule’s reach to the business community and the changes in environmental awareness, technology and business climate all merit modernization of the process.

    The goal of the proposed revised generator rule is to enhance the safety of facilities, employees and the general public by improving labeling of hazardous waste, which also can help with emergency planning and preparedness.

    The move to modernize is part of a trend at the EPA to become more strategic and data-driven in its approach to regulation across various areas of its environmental oversight. Within hazardous waste, this data-centric approach is evident in the newly relaunched Enforcement and Compliance History Online (ECHO) website, which houses data from inspections, enforcement actions and fines at facilities and businesses of all sizes across the country.

    In the past four years, EPA has conducted hundreds of inspections and levied more than $4.6 million in fines against SMBs — or “small quantity generators” that generate less than 2,200 pounds of hazardous waste per month. EPA actions for non-compliance include fines for violations such as mislabeling hazardous waste or improperly disposing of it.

    As the EPA continues to refine its approach regarding how facilities are classified, its increased reliance on data is likely to translate to a new regulatory atmosphere for SMBs.

    The rule change could substantially impact a business’ generator status. The proposed changes include replacing the phrase "conditionally exempt small quantity generator" (CESQG) with "very small quantity generator" (VSQG). This update aligns with the other two generator categories: large quantity generators (LQGs) and small quantity generators (SQG).

    Generator status and the fact that regulation and enforcement activity typically vary by state, county and geographic region makes compliance with hazardous waste disposal a complex issue for convenience stores and chains. In this time of regulatory change, ensuring the proper disposal of hazardous waste is a foremost concern for this business sector.

    Implementing an Effective Program

    In addition to ongoing communications with the private sector, EPA’s proposed change in hazardous waste regulation arises as other external influences combine to force businesses in the retail, healthcare and pharmaceutical industries to renew their focus around compliant disposal of hazardous waste.

    Consumers today are hyperconnected, socially aware and willing to research a business before spending their money. As many businesses know, in this consumer-driven economy, maintaining a customer’s loyalty is difficult. Much like data breaches that can compromise personal information and violate a customer’s privacy, a business that neglects to comply with environmental regulation governing hazardous waste risks the alienation of discriminating consumers who have endless choices about where and how they spend their dollars.

    Today’s leading convenience store retailers keep compliant with comprehensive retail hazardous waste disposal programs that serve their needs on a local, regional or even nationwide scale. Often working with third-party technicians, they also conduct hands-on, site-specific process and compliance training to instruct store employees on proper waste segregation and storage.

    To further ensure compliance and reinforce training, these leading retailers and their partners provide reference materials such as posters and literature for each location, and partners make regular site visits to manage and monitor waste management compliance.

    Although many brands have implemented hazardous waste management programs, the proposed regulatory change reflects increased awareness of the impact of hazardous waste on public safety and the environment. Convenience store retailers of all sizes should monitor the proposed change in generator status rules and determine how it impacts their hazardous waste management.

    A program that offers compliance, but that is also simple and flexible, can help a small business avoid EPA fines, maintain brand reputation, and keep employees and the public safe from improperly handled hazardous waste.

    Editor’s note: The opinions expressed in this column are the author’s and do not necessarily reflect the views of Convenience Store News

    By Mike Rozembajgier , Stericycle Environmental Solutions
    • About Mike Rozembajgier Mike Rozembajgier is vice president at Stericycle Environmental Solutions, a provider of environmental and regulated waste management solutions. Rozembajgier is responsible for all aspects of the company’s environmental service offerings, including development of strategic business initiatives and product enhancements. Prior to joining Stericycle, he held various management positions at Guidant Corp. (now Boston Scientific) and at Deloitte in its Strategic Consulting practice.

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