Environmental Protection

Setting Up a Digital Control Center

Integrated software systems can help organizations with multiple generation sites handle hazardous waste responsibilities more effectively

When considering entities that manage hazardous waste generated at a large number of generating sites, most people think of billion-dollar national or multinational corporations, with factories and facilities distributed over a wide area. But in fact, the category is much broader than that. In addition to these large corporations, entities with multiple generation sites also include numerous research, governmental, university and hospital organizations. This article examines models and tools available to help such organizations manage the generation, disposal, regulatory reporting, and economics of hazardous waste management.

Organizations with Multiple Generations
Although it is impossible to typify perfectly organizational structures, companies with multiple generators may be grouped into three general categories:

Definably dispersed generators: Organizations with multiple, but well-defined generation sites spread out over a wide area (the classic example is a national company with many plants, however, this category includes much smaller generators, such as gas stations or retail chains)
Geographically contiguous, but multiple generators: Organizations with many points of generation within relatively large, defined boundaries (e.g. laboratories, college campuses or military bases)
Unpredictably dispersed generators: Organizations that not only cover a wide area but also cannot predict exactly where they may generate wastes, especially in the form of accidental releases (e.g., utilities or pipeline companies).

Regulatory and Corporate Requirements
A large organization is typically responsible for managing its waste from two overlapping levels. From a regulatory perspective, the organization is required to manage the generating facility: make waste determinations, maintain storage areas and waste profiles, mark its drums or containers, respect storage time limitations, and ship the materials using qualified transporters to permitted facilities on hazardous waste manifests. In addition, annual or biennial regulatory recordkeeping and reporting requirements must be completed.

From a corporate perspective, the organization is required to track costs for waste management, manage personnel involvement (including training), manage samples and analyses for waste determinations, oversee contractors, and fulfill a variety of environmental mandates that have been handed down from corporate directors and shareholders. These requirements are summarized in Table 1.

Table 1: Key Regulatory and Corporate Hazardous Waste Management Requirements
Requirement Description
Regulatory Requirements
Waste determination and profiling. • Determine whether the waste in question is hazardous.
• If hazardous waste, determine the waste codes, Department of Transportation shipping descriptions, and other key descriptors.
Labeling/ marking. Label and mark drums and containers correctly.
Set up proper storage locations. Create and partition storage locations to store and segregate wastes.
Respect storage time limitations. Avoid storing waste for longer than permitted (90 or 180 days typically).
Arrange for shipment. Arrange for shipment of materials to permitted treatment, storage and disposal facilities (TSDFs) using qualified transporters.
Reporting and recordkeeping requirements. Maintain manifests and annual generation data.
Corporate Requirements
Track Costs Invoicing; accounting; cost allocation across organization.
Waste reduction Generation records; reduction technologies; measurement.
Manage personnel Training; personnel assignments.
Sample management Labeling; chain of custody; sample data usage.
Oversee contractors Contact management for legal approval for transporters and TSDFs (corporate liability).
Fullfill corporate environmental mandates Track mandates; measure current and future performance; public relations.

In order to fulfill these requirements as efficiently as possible, it also is important to consider the type of overall environmental organization and management. Attributes of each of the three types of organizations are listed in Table 2. There is some overlap between these categories and their attributes. Even well-defined organizations occasionally require spill response, for example, but that is not the usual way they operate.

Table 2: Attributes of Each Type of Organization
Type of Organization Typical Examples Typical Attributes
Definably dispersed generators. • Chemical companies.
• Manufacturers.
• Distributors
• Some large retailers.
• Multiple large or small quantity generators spread out over a wide area.
• Organizations have multiple U.S. Environmental Protection Agency (EPA) IDs.
• Distributed waste management responsibilities.
• Concerns include quantities of material, cost and cost accounting and liability.
Geographically contiguous, with multiple generators. • Laboratories.
• College campuses.
• Government campuses.
• Multiple generators, typically very small, across a defined area.
• Usually one EPA ID for entire area.
• Usually serviced by a single group.
• Typical concerns include exotic or very toxic chemicals and solvents.
Unpredictably dispersed generators. • Utilities.
• Road maintenance organizations.
• Multiple points of generation, not well-defined.
• Sometimes combination of defined sites (e.g. power generating sites) with unpredictable points of generation (e.g. a substation or even individual light pole with transformer).
• High percentage of generation occurs with spill or maintenance activities
• Typical concerns include spill response, sample management, cost containment, and team/ personnel management.

Centralizing with a Data Management System
One of the first questions that organizations should ask is not so much whether to centralize hazardous waste management, but the extent to which it should be centralized. In general, most organizations gain from more centralized management in terms of personnel and efficiency. However, they do so at the risk of losing control or not maintaining their compliance at a local level. Information systems that allow for oversight across multiple levels of the organization can reduce that risk while at the same time improving efficiency from more centralized management. Table 3 summarizes management methods across each of the three categories of organizations.

Table 3: Management Methods for Each Generator Category
Organizational Structure Definably Dispersed Generators Contiguous with Multiple Generators Unpredictably Dispersed Generators
Local vs. Centralized Management Varies between centralized and management at the plant level. • Significantly more efficient to centralize.
• Often these organizations have an internal TSDF or loading dock where waste is aggregated before shipment.
• Often contracted.
• Some organizations employ a ‘service request’ system so generators can request pickups.
• Other organizations ask generators to put the waste in a special bin.
• Generally centralized (spill and maintenance response require a central organization to manage).
• However, often with multiple ‘teams’ dispersed geographically.
Cost-Sharing • Generally the local plant pays.
• However, may be complicated by multidivision or product line plants.
• Costs accrued at the central location.
• Budget allocation usually by total waste generated by each generator.
• Rarely, more sophisticated approaches that take into account individual waste stream disposal costs are used.
• Costs accrued and managed centrally.
• Sometimes cost split between ‘maintenance’ and waste management.
Responsibility for local compliance • Normally rests on the plant manager or designee.
• Often contracted out, introducing more layers.
• Assistance/ inspections may be provided by central management group.
• Corporate concerns include storage time limitations, use of approved vendors, and waste identification.
• Local areas are responsible for identifying chemistry.
• Central organizationshandles profiles and approvals by TSDFs.
• Normally, as little as possible is asked of generators.
• Central organization (‘corporate’) is responsible.
• Maintenance organization often reports issues and spills, which are then passed to the environmental group.
• Emphasis is on response to reduce or eliminate public exposure.
Annual compliance requirements • Management varies considerably among organizations.
• This is usually the first function to be centralized, otherwise, it is handled by the plant environmental manager.
• Managed centrally.
• At generator level, these too are tracked centrally (part of the service provided by the central waste management team).
• These are complicated by the need to report across different media and the ‘reactive’ nature of the management.
Cost controls • Source reduction efforts have reduced costs considerably.
• Costs may be managed either centrally or locally.
• Cost containment efforts include centralized contracting with transporters or TSDFs.
• Generally high per unit of waste (must maintain facility and staff for relatively small volumes).
• Usually managed centrally.
• Disposal costs high due to nature of chemicals.
• One area to contain costs is coordination with purchasing to reduce chemical wastage.
• Managed centrally, often with coordination with maintenance.
• Cost controls include spill prevention (maintenance), laboratory management, improved coordination and team management.
Compliance with corporate directives • Usually centrally.
• It can lead to conflict if waste management is not centralized as well.
• Managed centrally.
• Statistics relatively easily maintained, but no real controls over generation.
• Managed centrally.
• Difficult to control generation.

In all cases, a central data repository gives the organization more flexibility in organizing its approach to waste management. This flexibility allows the organization to select more cost-effective organizational and management approaches because the system can easily be used across all levels of the organization, minimizing data re-entry and maximizing the value of the data.

For day-to-day management, such systems should include:

• Access anywhere, anytime for all applicable personnel
• Task management to automatically create follow-up tasks when certain events occur and to manage team members’ activities
• Alerts for potential storage time violations
• Ability to create and manage generators
• Full waste profiling and characterization
• Waste tracking and management – including containers, labpacks, and tanks
• Vendor tracking and management
• Price and cost tracking
• Sample management
• Approval controls regarding where waste is shipped
• Shipment tracking for both container and bulk shipments
• Manifesting

For longer-term management, the systems should include:

• Configurable security to control access to the system (according to the organizational structure)
• Full reporting, including annual generation reports
• Ad hoc reporting capabilities to produce management reports
• Source reduction tracking and reports
• Ability to track facility approvals and audit reports
• Ability to integrate with other environmental packages
• Customizable screens for data entry

For example, many organizations use the Enviance System, the market’s only compliance management solution utilizing the Software-as-a Service (SaaS) model, for managing wastes. SaaS systems, such as the one manufactured by Enviance, are purchased on a subscription basis depending on the organization needs at the time of the initial subscription and can be adjusted depending on the fluctuating growth of the operation. The integrated system allows facilities to centrally manage and automate in real-time all aspects of compliance from an Internet browser. This system significantly improves facility operations by automating procedures and eliminating paper trails. The off-site software manufacturer handles all facets of data collection, management, storage and security.

Such integrated software tools enable organizations with multiple generators to manage their waste in the most efficient and cost-effective method possible. For example, a geographically dispersed generator gains flexibility because larger plants with their own environmental staff can manage their wastes locally, while smaller generators may have their waste managed from a headquarters. At the same time, the organization gains the ability to contract centrally for waste management services, and review and monitor compliance as well. Finally, costs are easier to allocate among divisions or product lines, providing added incentives for waste reduction.

Each of the three types of multiple generators has its own challenges for managing and tracking their hazardous wastes. An integrated software management system that centrally houses the organization’s data can assist in meeting compliance needs efficiently and cost effectively.

This article originally appeared in the 04/01/2007 issue of Environmental Protection.

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