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As a convenience store owner or operator, you may not think of yourself as a hazardous waste producer, but that does not necessarily mean you are exempt from special waste handling, containerization, labeling and disposal processes dictated by regulation such as the Resource Conservation and Recovery Act (RCRA) and state laws.
Given that waste management is generally not a core competency of c-store managers, the following answers to frequently asked questions (FAQs) will help you get on the right track — and stay on the right side of regulators.
Why would a convenience store need a hazardous waste management program?
Even if you do not generate hazardous waste as part of your daily operations, if you discard or accept returns of products containing corrosive, ignitable, toxic, reactive or persistent materials, for example, you still need to comply with hazardous waste management regulations.
Whether you need to discard of a few bottles of motor oil and antifreeze at your fuel station, or aerosol cans and cleaning products in your convenience store, you are responsible for managing that waste appropriately.
What could happen if we do not comply?
If you are not aligned with waste management regulations today, you are far from alone, but that does not mean there are no consequences. Some of the largest retailers in the world have been warned, fined or suffered brand reputation damage when regulators determined their waste management programs were not in compliance with existing standards, and the same could happen to anyone in a similar situation.
What challenges must be overcome?
Comprehending what qualifies as "hazardous" based on regulatory language can be confusing, not to mention grasping the intricacies of the entire waste management process.
Other challenges inherent to establishing a waste management program include:
- Lack of knowledge and qualification to develop compliant waste management processes on-site;
- Lack of training on complex subject matters for an inexperienced workforce spread across locations;
- Lack of space in convenience store back rooms meant to hold inventory, not containerized hazardous waste; and
- Lack of willingness on a corporate, franchise or local operator level to maintain environmental compliance.
What is required to keep convenience stores compliant?
The first step is to begin sorting your waste, categorizing materials based on their hazardous designations in clearly labeled containers. Depending on the amount of hazardous waste generated at a site on a monthly basis, a licensed professional may also be required to pick up the waste before compliantly transporting and disposing of it.
Documentation regarding waste quantities, timing, transportation and more is required for every step of the waste management process so that you can prove you are doing so.
What if we do not have the resources to manage waste effectively?
Many retailers choose to work with hazardous waste management experts when forming a waste management strategy and executing it. Waste management compliance program providers not only have a strong understanding of environmental waste management rules, but also may have many years of experience working with retailers across the country on similar programs.
They can help you properly identify waste, create an organized collection space, choose the right variety of containers, and find a disposal frequency that meets your needs. Often, they help you manage waste more cost-effectively than if you attempted to do so on your own.
To ensure strong results from the partnership — and the subsequent program you put in place — here are a few dynamics to consider upfront:
What is the partner’s ability to get the job done right and in a timely manner?
Look into their qualifications and track record of handling hazardous waste for similar companies; customer perceptions of reliability and the partner's ability to meet needs in a timely manner; and provider strength of documentation and ease of access for mandatory reporting information. Also factor in clarity of waste management system approaches and ease of adoption across your locations; whether value-added services, like shipping manifest proxy signing, are offered to streamline service delivery; and existence of offerings related to both urgent and emergency response services in the case of hazardous waste emergencies.
You are relying on a waste management partner because they know applicable state and federal regulations better than you do.
Find out how much experience a provider has dealing with hazardous waste, the retail sector, and specifically convenience stores; what sort of in-house expertise they have regarding the specific regulations that govern your operations; and how they have helped customers find ways to minimize waste and reduce costs over time.
Ultimately, your employees will need to play a part in handling and categorizing waste.
The more stores you operate, turnover you experience or knowledge you lack around environmental compliance, the more understandable and easily reproduced training must be. Compliance program providers that offer a "train the trainer" program are desirable, as this allows specific company representatives to gain the knowledge needed for a successful program, and then train employees on the store level.
While it is hard to quantify, the level of service you will receive is one of the most important (and overlooked) aspects that will define your experience with a waste management partner.
When your backroom space, internal regulatory understanding and ability to respond to emergency situations is limited, level of responsiveness and dependability of your partner matters significantly.
Look into the company's history of customer service; timeliness of service delivery; flexibility in extraordinary situations; proactive approaches to improving operations; and geographic coverage to provide convenient service.
How do we get started?
Sometimes, there are added frustration-related "costs" that go along with choosing the lowest-cost provider every time, so do your research.
If you do not currently have a compliance program in place with regard to hazardous waste disposal, it is only a matter of time before regulators will take notice. While hazardous waste management compliance may seem complicated, it does not have to be with the right partnership in place. Start by researching waste management program providers and satisfaction levels of current clients, then start a conversation around becoming compliant.
Editor’s note: The opinions expressed in this column are the author’s and do not necessarily reflect the views of Convenience Store News.