Assessing the Compliance of Disposal Sites and Key Compliance Indicators


Assessing the Compliance of Disposal Sites and Key Compliance Indicators

When determining whether to trust a disposal site to process and dispose of your company’s waste, its crucial to have system in place to assess the sites compliance. Utilizing different avenues to determine compliance, along with key compliance indicators to check, you’ll set your company up for success when making this important decision. Outlined below, are different items to consider:

Conduct a site visit

There is added benefit to visiting a disposal site in person when deciding to partner with them to handle your waste. An in-person visit allows insight to things you wouldn’t otherwise learn; it provides an opportunity to talk to the staff as well as physically see waste get processed.

Review the facilities permits and corresponding applications

Looking at a facilities permits can provide a lot of information, however, sometimes it’s important to look at the permits corresponding applications. Many permits are written in a way where they reference the application or additional attachments. In these situations, its crucial you request these items from the facility, for specific waste streams.

Utilize state agency compliance and permitting portals

Many states have portals with compliance and permitting information and resources. For example, New Jersey, California, and Pennsylvania all have great portals that are regularly updated. These portals allow you to see compliance history, copies of permits, copies of correspondence regarding Notice of Violations (NOVs), and compliance inspections.

Hire a vendor or consultant to conduct site assessments and disposal vendor audits

CHWMEG is a paid service, highly used by the larger fortune 500 companies to assess compliance. Members can access the audits they conduct on disposal vendors. Hiring a consultant is another option; just ensure they ask the disposal facility for audit packages, copies of permits, insurance, and health and safety performance.

Talk to the disposal vendors’ inspectors

If the facility is reputable, they shouldn’t have an issue with you talking to their inspectors. It’s probable that they ask to be on the call while speaking to the inspector, however, you can still ask the inspector questions to determine the facilities compliance.

EPA Echo

The EPA’s Echo site is an online portal for the compliance of regulated facilities and can be a good starting place. Information such as how facilities are regulated, when they were last inspected, and past violations can all be found here.

Key compliance indicators

It’s crucial to have tools to assess compliance, but how do you know what to look for? Here are a few key compliance indicators to monitor when assessing compliance:

  • Regulatory compliance history
    • Repeat administrative or operational violations may indicate the mishandling of material, improper paperwork, and lack of corrective action.
  • Site visit
    • Housekeeping is an indicator of how material is managed; if the place looks disorganized, you may have reason to question.
    • Recordkeeping is critical. Ask to look at profiles, manifests, and disposal certificates.
  • Processing turnaround time
    • Processing turnaround time will tell you if the facility’s disposal process lingers. If so, you may want to question why that is.
  • Staff Knowledge
    • Quizzing staff on their knowledge of permits, compliance, and health and safety performance can give insight on how they will handle your waste.

The information, content and materials provided in this Assessing the Compliance of Disposal Sites and Key Compliance Indicators blog and in related materials (“Content”) does not, and is not intended to, constitute legal advice, nor is it prepared by lawyer or law firm or as the product of any attorney-client relationship. Content is provided "as is;" no representations are made that the content is error-free. Content is available for general informational purposes only and may not constitute the most current legal or other information. Recipients of the Content assume all responsibility and risk arising from its use and reliance upon the Contact and should contact an attorney to obtain advice before acting or refraining to act on the Content. All liability with respect to actions taken or not taken based on the Contents is hereby expressly disclaimed.

Take the next step
To create a better future for our people, partners, and planet