The Retrofit Companies Blog

Choosing a Reputable Partner Minimizes Your Risks for Regulated Waste Related Fines

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One of the most important concepts for generators of waste to understand is Cradle-to-Grave.  You can see the EPA’s definition HERE.  But, in a nut shell, this means that the generator of waste is responsible to ultimate disposal.  Nothing will relinquish a generator of this responsibility and there’s no expiration date or time limit.  Hiring someone else to transport and dispose of your waste does NOT transfer responsibility. 

Read more: http://www.businessdictionary.com/definition/cradle-to-grave.html

 

Recently, charges have been filed against two vendors who were previously trusted to properly handle their clients’ waste.

Luminaire Environmental and Technologies Inc. Plymouth, MN

http://www.startribune.com/plymouth-waste-disposal-operators-charged-in-fraud-scheme/446253773

Recycletronics Sioux City, IA

https://resource-recycling.com/e-scrap/2017/08/17/sioux-city-crt-stockpiles-prompt-enforcement-action/

Because the actions of your chosen vendors can also negatively affect your company image, as well as result in fines and other additional fees for you, it’s important to know the following about anyone you allow to manage your regulated waste:

  • Can they provide names and contacts to current customers (similar to you) as references?
  • Does the vendor have adequate insurance? They should be able to provide not only commercial liability, but also pollution coverage.
  • Where does the waste go? Can the vendor provide all downstream channel and facility information?
  • What documentation and paperwork is provided? Depending on the waste type, waste profiles and hazardous waste manifests may be required. Certificates of Recycling/disposal should be provided every shipment, and your vendor should be able to provide you with usage reports, as requested.

You should be prepared and have a plan. [Check out our blog for help preparing a waste management plan.] Monitor and manage your plan, and the service provided to ensure you are in compliance should never be overlooked.

At The Retrofit Companies, your environmental compliance is our top priority. We offer a range of environmental services, assisting with material inventories, legal documentation, and access to approved packaging options. In addition to proper shipping procedures and an extensive network of disposal partners, rest assured that your waste handling and recycling needs are covered by TRC. We're here to be the hazardous waste recycling and disposal partner you are looking for.  

Consult our haz waste team

 

Minnesota Hazardous Waste manifest Updates

Although TRC sent notices along with all the manifests that we generated earlier this year, it may be a good reminder to Minnesota generators that the MPCA is no longer requiring you to mail in the  “Designated Facility to generator’ (3 signature copy) manifest copies. Generators in Scott and Anoka counties still need to send in their copies to their respective Counties.

 

“For administrative and budgetary reasons, the Minnesota Pollution Control Agency (MPCA), and the Metropolitan Counties of Anoka, Carver, Dakota, Hennepin, Ramsey, Scott, and Washington (Metro Counties) have changed the requirements for submittal of hazardous waste manifest copies.

Effective April 30, 2016, all hazardous waste generators of any size in Anoka and Scott counties must submit manifest copies directly to their county.

Hazardous waste generators of all sizes anywhere else in Minnesota except Anoka or Scott County should no longer submit any manifest copies to either the MPCA or their county unless explicitly requested.

You may find a detailed discussion of this change in newly revised MPCA Factsheet #w-hw1-07, ‘Manifest Shipments of Hazardous Waste’ at:

 

https://www.pca.state.mn.us/sites/default/files/w-hw1-07.pdf "

 

 Questions about compliance or waste solutions? Contact our team today!

Consult our haz waste team

MPCA Rule update for Haz Waste Paperwork Burden

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A new rule was handed down from the MPCA (Minnesota Pollution Control Agency) affecting hazardous waste generators in some metro area Minnesota counties. In short, it relieves some of the paperwork burden for our hazardous waste generator customers.

With the exception of Anoka and Scott counties, generators are no longer required (unless specifically told to do so) to send any copy of a Uniform Hazardous Waste Manifest in to the MPCA.The requirement for mailing three signature copies to Anoka and Scott counties does not apply to PCB manifests. In all instances it is still required that all generators retain copies of all Manifests for a minimum of 3 years. Read on for more details and links:

 

Do I have to send copies of my manifests to anyone?

*As of April 30, 2016, the MPCA and Carver, Dakota, Hennepin, Ramsey, and Washington Counties no longer require generators of any size to send any manifest copies to them, unless explicitly requested. Do not submit a copy unless explicitly requested. Copies voluntarily submitted will not be reviewed or retained.

All generators of any size in Anoka and Scott County must submit a copy of the Designated Facility to Generator Copy (3-signature copy) to their county within 40 days of the designated facility’s receipt of the waste.

Note: The submittal requirements for Anoka and Scott County do not apply to manifests used for shipping only PCB wastes. Instead, keep these copies in your records and ensure you meet any additional PCB requirements. See MPCA fact sheet #w-hw4-48d, Manifest and Dispose of PCBs, at: https://www.pca.state.mn.us/sites/default/files/w-hw4-48d.pdf.

 

Learn more about Manifest Shipments of Hazardous Waste with this guidance document.


If you have specific questions about this rule or others, you can contact our Haz Team any time!

 

Consult Hazardous Waste Professionals

 

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