Sustainable management of hazardous waste issues, Solutions!, Online Exclusives, September 2004

online exclusives

SUSTAINABLE MANAGEMENT OF HAZARDOUS WASTE ISSUES

By Rebecca Pehler, Webb, Murray, and Associates

For structured maintenance of issues associated with the transport, storage, and disposal of hazardous waste, every business needs an effective environmental management system (EMS). Business management has a responsibility to assure that stakeholders (employees, contractors, company personnel, and the public) understand issues of awareness and performance associated with hazardous waste. The environmental management system should be a documented testimony to “this is who we are and this is how we work” that describes the nature and operations of the business.

Out of concern for the future, the management of hazardous waste must be sustainable. Sustainability, and in many cases the license to operate for business, is defined by its Health, Safety, and Environmental (HSE) commitment and policy. Additionally, sustainability is the action of business in response to HSE issues that affect employees, contractors, stakeholders, and the surrounding community. By having a management system (MS) in place, these HSE issues are evaluated and worked on a sustainable basis. In other words, present day operations of business do not hamper future performance. The MS is in place to manage risk associated with hazardous waste management.

Some elements of sustainability include:

  1. Economic: Business stays profitable in supporting the generation of jobs and technology.
  2. Social: Assuring the safety and working conditions of employees that help and sustain the job and business.
  3. Environmental: having in place an MS. Having an increased awareness of the xisting controls of the job that assist in preventing environmental impact.
  4. Product stewardship: Responsible use of products; minimizing waste; reducing energy consumption.

Overall the MS (both EMS and HSE MS) have considerations including:

  • Objective and target setting: Define the inputs into formulating objectives and targets such as: audit results, stakeholders, and environmental impacts of operations.
  • Risk management: Awareness of both actual and potential impacts to the environment of doing the job; groundwater and soil contamination; release of pollutants into nearby waters; actual and potential damage to ecosystems; actual and potential release to the environment; exposure to employees and non-employees. What is acceptable risk and how will it be measured? How will mitigation be approached?
  • Policies, plans, and setting of the business direction: Setting of responsibilities, accountabilities, and authorities for work. How will training maintain this?
  • Organization and resources: Documentation and communication of responsibilities, accountabilities and authorities of work.
  • Standards and procedures: Periodic review as an assurance that standards are being met. Key procedures are based on performance and target settings of the business. Document control is in place.
  • Audits: Looking at outcomes caused by behaviors that are caused by MS weakness.
  • Implementation, monitoring and corrective action: Repeat findings of non-conformance? How is this correlated to the MS?
  • Management review: Assess performance by review of audits, corrective action, meeting objectives and targets; also review input of stakeholders (employees, non-employees, community, and regulatory concerns) who are included in the business target and setting of objectives.

The management system lends value by increasing awareness of work flow that defines the business. Work flow is defined as the inputs and outputs of the work function or job:
Input: Who and what is needed to do the job?
Output: Who and what relies on the product or service resulting from doing the job? Are customers and stakeholders being satisfied when the job is done?

Work flow processes in a MS are maintained by:

  • Awareness of the work flow’s impacts that have both an actual and potential to adversely impact or benefit the environment. By knowing this information, the business can better formulate an environmental policy or HSE policy that identifies priority items to address so that objectives and targets are met.
  • Environmental or health and safety issue of corrective action to solve work flow issues of nonconformance. There must be assurance that procedures or methods are in place to:
    • Identify the issue of nonconformance in the work flow.
    • Be aware of and implement appropriate corrective action. Once corrective action is undertaken, all related procedures and documents are updated.
    • Assure that quality control systems are in place. Are the controls and procedures adequate to insure that these problems of nonconformance do not arise again?
  • Having sufficient resources to maintain the work flow in the areas of implementation, monitoring and measuring, tracking, and frequent specified management reviews.
  • Self-assessment, resolution and subsequent tracking of environmental or health & safety issues. Designating individual responsibilities and data storage systems.
  • Being aware and maintaining communication with stakeholders concerning the inputs and outputs of a specific work flow. In other words, knowing who is responsible for what, who needs what, and to whom does the finished work flow go.

Controls of the MS describe the collective work flows and objectives of the business, while responding to changes in both the business and regulatory climates. This is documented in a manual for purposes of communication and awareness to all relevant stakeholders of the business. The components of the MS, or controls, also provide value to business management in monitoring and measuring HSE performance and achieving continuous improvement.

When the EMS is expanded to include Health and Safety (HSE MS), the HSE MS will drive everyday business decisions. Management will then have a more focused and cost-effective use of sometimes limited resources. Additional benefits include, but are not limited to: improved risk analysis, consistency of documentation, and minimization of business environmental impact. This is needed for sustainable management of hazardous waste issues of business.

About the Author:
Rebecca Pehler is a degreed chemical engineer and chemist with more than 24 years of diverse experience working in the Gulf Coast area. She is a health, safety, and environmental management system consultant for Webb, Murray, and Associates, Inc. of Houston, Texas. Her experience base includes working in the areas of: projects, process, research, operations, safety, and the environmental field. Questions and comments can be directed to: pehler@kingwoodcable.net.

Author: Pehler, R.
Sustainable management of hazardous waste issues, Solutions!
Sustainable management of hazardous waste issues, Solutions!, Online Exclusives, September 2004
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