Proper disposal of hazardous waste is always essential, but particularly during a global public health crisis. Though changes to business operations may be unprecedented, compliance is still essential: a national emergency does not provide blanket relief to environmental regulations.
We recently held a webinar around environmental compliance during this unprecedented time. Below, we’ve highlighted key points from the presentation about maintaining compliance and business continuity in the COVID-19 era to help you plan for specific challenges that may arise.
Regulatory Climate and Relief
Since regulatory agency offices are likely closed with staff working remotely, expect delayed responses to inquiries and enforcement actions, and onsite inspections will transition to desktop/paperwork compliance reviews. Also expect significant delays of state legislative and regulatory activity. For example, adoption of Generator Improvement, Pharmaceutical and Universal Waste Aerosol Rules will be affected.
It’s crucial to regularly check updates from state and local agencies to stay informed. Their websites will publish instructions around handling operations remotely, including submitting fees and permits electronically and announcements around enforcement discretion.
Again, environmental regulators will expect full compliance unless relief is requested or enforcement discretion is announced. This presents challenges if, for example, store closures may mean accumulation time limits are exceeded, weekly inspections aren’t completed or accumulation containers are left open.
The best way to prevent noncompliance penalties is to get ahead of the situation by scheduling compliance services before your business closes, developing pandemic protocol training for essential staff, contacting regulatory agencies for guidance and documenting the steps you’re taking to maintain compliance.
COVID-19 Waste Overview
The CDC and OSHA have released specific waste-related guidance around COVID-19. Regulated medical waste (RMW) facilities are equipped to manage all COVID-19 related RMW waste. Hazardous waste, including pharmaceutical waste, may need to be rerouted to other properly permitted facilities for disposal.
State agencies as well as The Healthcare Waste Institute have issued guidance for managing COVID-19 waste, while the EPA has published a list of disinfecting chemicals effective against COVID-19.
Business Continuity and Contingency Planning
A recent Department of Homeland Security memo identified several waste-related employees as essential to the COVID-19 response, from truck drivers who haul hazardous waste, to workers who manage waste from medical and pharmaceutical facilities. Be sure to follow these guidelines to ensure compliance with federal regulations.
Remaining vigilant around regulations amid the COVID-19's crisis mitigates safety risk to workers, the environment and our communities during this time of uncertainty. To learn more about how Clean Earth can help, please visit our Coronavirus Emergency Response page.
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