hazardous waste management program - vetco clinics...clinics generate most offices will only have...

of 13

Hazardous Waste Management Program

OVERVIEW This program is designed to support the Vetco Mobile Veterinary clinics as well as the in-house

clinics in the management and handling of Federal (RCRA) and State regulated hazardous and

universal waste. These materials are accumulated from clinic operations and are not permitted

to be disposed of in the regular trash. This program is designed to help identify, handle,

manage, and store hazardous and universal waste items based on federal, state, and local

regulatory requirements.

Purpose The purpose of this Hazardous and Universal Waste Management plan is to provide guidance

to all Vetco partners on the work practices and related activities that must be followed in order

to comply with the hazardous waste regulations and best management practices applicable

to the facility.

Regulatory Applicability When a product (i.e. expired cleaners, partially used vaccines etc.) is deemed no longer be

usable for its intended purpose, has spilled or has become “otherwise” unusable it is then

considered a Hazardous Waste. If it is determined that the hazardous material has become a

hazardous waste, then the facility is subject to the Federal Standards for the Management of

Hazardous Waste in Title 40 Code of Federal Regulations (CFR) Parts 260 through 279 defined by

the Environmental Protection Agency (EPA).

In accordance with Vetco’s hazardous waste management program, this facility is subject to

the following regulatory requirements as defined by EPA in Title 40 of the CFR in subsection 262:

• Stores less than 13,200 pounds of hazardous waste at any time.

• Ships hazardous waste to an appropriate waste treatment, storage, or disposal facility

within 180 days of the accumulation start date. The moment a hazardous waste item is

placed into a container, a date is entered (accumulation start date) on the hazardous

waste label and within 180 days the container must be shipped offsite.

Audience Vetco has developed this hazardous and universal waste management plan to comply with

Federal, State, and Local regulatory requirements. This plan was developed to ensure that all

Vetco partners and contract staff are equipped to successfully manage the program and

maintain compliance with Federal, State, and Local regulatory requirements at all times.

HAZARDOUS & UNIVERSAL WASTE MANAGEMENT PLAN

of 13

CONTENTS OVERVIEW .......................................................................................................................................................................................................... 1

CONTENTS ........................................................................................................................................................................................................... 2

POLICY ................................................................................................................................................................................................................ 3

ROLES & RESPONSIBILITIES ................................................................................................................................................................................. 3

WHAT IS A HAZARDOUS WASTE? ..................................................................................................................................................................... 4

HAZARDOUS WASTE CONTAINER MANAGEMENT ......................................................................................................................................... 6

SPILL RESPONSE EQUIPMENT AND CLEANUP ................................................................................................................................................. 9

HAZARDOUS WASTE STORAGE AREA WEEKLY INSPECTIONS ..................................................................................................................... 10

HAZARDOUS WASTE PICK-UP PROCESS ........................................................................................................................................................ 11

TRAINING .......................................................................................................................................................................................................... 12

RECORDKEEPING ............................................................................................................................................................................................. 13

RESOURCES ...................................................................................................................................................................................................... 13

Revision History

Date Ver. No. Summary of Changes

09/2015 0 First Issue

12/2017 1 Updated to sections per Vet recommendations


of 13

POLICY

It is Vetco’s policy to ensure that, Vetco facilities comply fully with all applicable

environmental laws and regulations. Vetco believes that minimizing the impact on the

environment is the responsibility of all businesses and Vetco fully agrees with this

responsibility. Vetco is committed to complying with applicable environmental laws and

regulations. Vetco partners are expected to use all resources appropriately and efficiently

and make every effort possible to protect the environment. Vetco believes that it is our

duty to take an active role in building a better world

ROLES & RESPONSIBILITIES

Each Vetco office and in-store clinic is equipped with a team of Vetco Partners who will

oversee the Hazardous Waste Program and ensure compliance through receipt of proper

training and daily implementation of the various elements of the hazardous waste

program. The roles and responsibilities of the Hazardous Waste Program Team are as

described below.

Corporate Environmental, Safety and Health

The Corporate Environmental, Safety and Health staff will provide the following support

services/activities to Vetco offices and in-store clinics to ensure compliance with Federal,

State, and Local requirements.

The Corporate Environmental, Safety and Health staff is responsible for the following:

1. Obtain the EPA Identification Number for the facility if applicable.

2. Contract with a hazardous waste contractor to transport hazardous waste to an

appropriate storage, treatment, and/or disposal facility.

3. Develop a training plan in accordance with the requirements found in 40 CFR

262.34(d)iii) and provide training materials and guidance to each facility.

4. Prepare and maintain the Hazardous Materials Business Plan (HMBP) where

applicable.

5. Complete all required reporting activities associated with the generation of

hazardous waste.

6. Assist with regulatory reporting for releases or spills of hazardous waste.

Facility Responsibilities

Vetco must ensure that all partners are thoroughly familiar with the proper waste

handling and emergency response procedures relevant to their responsibilities during

normal facility operating hours. The following outlines the key responsibilities of Vetco

partners involved in the hazardous waste management program:

Lead Hazardous Waste Manager- (Market Manager or Store Leader)

1. Ensure proper setup of the Hazardous Waste Storage Area.


of 13

o For In-store clinics they will be using the store’s Hazardous Waste set up in their back

room. They will work in conjunction with the Store GM

2. Complete appropriate hazardous waste training.

3. Facilitate the General Hazardous Waste Awareness training for all Vetco partners.

4. Assist when needed in sorting all hazardous waste items into appropriate waste

containers.

5. Manage hazardous waste vendor pick-up.

6. Manage hazardous waste documentation and complete the Hazardous Waste

Storage Area Weekly Inspection Log.

Janitorial Support Contractor

1. Dispose of hazardous waste legally and properly, do not dispose of

hazardous waste into trash receptacles or compactor.

2. Complete the General Hazardous Waste Awareness training supplied by

contractors’ leadership.

3. Call for assistance on spills or releases of hazardous waste.

Partners

1. Do not dispose of hazardous waste without the guidance from your

Manager. Do not dispose of hazardous waste into trash receptacles or

compactor.

2. Complete the General Hazardous Waste Awareness training.

3. Call for assistance on spills or releases of hazardous waste.

WHAT IS A HAZARDOUS WASTE?

A hazardous substance is any solid, liquid or gas that can threaten human health or the

environment. A hazardous waste is a waste with properties that make it potentially

dangerous or harmful to human health and the environment. Hazardous wastes can be

the by-products of manufacturing processes, discarded used materials, or discarded

unused commercial products.

In regulatory terms, a hazardous waste is a waste that appears on one of the four

Resource Conservation and Recovery Act (RCRA) hazardous waste lists (e.g. “Listed

Waste”) or that exhibits one of the four characteristics of a hazardous waste (e.g.

ignitability, corrosivity, reactivity, or toxicity).

• If a waste meets the criteria of being a hazardous waste, all the requirements for

hazardous waste management must be met to ensure safe and protective handling,

including: storage, transportation, treatment and disposal.


of 13

HAZARDOUS WASTE CONTAINER MANAGEMENT

Federal and state regulations govern how Vetco offices must manage hazardous waste.

Disposal of hazardous waste in the regular trash or down any drain is prohibited. The

proper handling and storage of hazardous waste is critical to maintaining a safe

environment for Vetco partners, as well as ensuring compliance with federal, state, and

local regulations.

Vetco Offices are considered Conditionally Exempt Small Quantity Generators (CESQG)

of hazardous waste. By definition, a CESQG of hazardous waste is a facility that

generates less than 220 pounds of hazardous waste per calendar month, and/or less than

2.2 pounds or less of acutely or extremely hazardous waste per calendar month.

Conditionally Exempt Small quantity generators of hazardous waste may accumulate

hazardous waste onsite for up to 180 days (6 months) or less without requiring coverage

under a hazardous waste permit.

All hazardous waste must be collected, accumulated, and stored prior to shipping in

appropriate containers to an offsite, treatment, storage and disposal facility (TSDF).

Proper handling and storage of hazardous waste is critical to maintaining a safe

environment for Vetco partners and to the successful execution of the hazardous waste

program.

Accumulation Area

Each Vetco Office must designate a hazardous waste accumulation area for the

management of hazardous and universal waste. The accumulation area must be

designed to ensure that hazardous waste is correctly stored until it is picked up the

Vetco’s licensed hazardous waste disposal vendor.

Hazardous waste generated by the mobile clinics must be accumulated in appropriate

containers and incompatible waste streams must be segregated as follows:

1. Toxic liquid/solid

2. Acids (Corrosive)

3. Flammable Waste Only

4. Alkaline (Corrosive)

5. Aerosols

6. Universal Waste Lamps

7. Universal Waste Batteries

8. Universal Waste Electronic

Devices

9. Non RCRA Regulated

Materials


of 13

Containers used for waste accumulation must be maintained in good condition (free

from holes or cracks), compatible with all contents, and properly labeled. Containers

are to remain closed, except when adding or removing hazardous waste (40 CFR §

265.171-174.) The accumulation area must be kept well-organized and tidy, with clear

access at all times.

In addition, hazardous waste accumulation areas will also include the following:

1. Spill Response Equipment: gloves, pads, absorbent, etc.

2. Hazardous Waste Signage:

• Hazardous Waste Collection Area Signage

• Hazardous Waste Management Poster

Labeling

Federal law (40 CFR § 262.34) requires that all containers used for hazardous waste

accumulation be marked with the words “Hazardous Waste” and the date upon which

each period of accumulation begins. Additionally, each container must be labeled with

the following information:

1. Chemical name

2. Composition and physical state of the waste

3. EPA ID Number if applicable

Vetco Offices


of 13

4. Statement(s) calling attention to the particular hazardous properties of the waste

5. Name and address of Vetco Distribution Center or Store generating the waste

Hazardous waste labels contain vital information about the Vetco and the waste

contained within each container. These labels must be clearly visible at all times. There

are variations on the types and colors of hazardous waste labels available for use. These

are color coded based on waste stream. Due to the limited amount of waste that Vetco

clinics generate most offices will only have 1-2 waste streams.

The Lead Hazardous Waste Manager or his/her designee is responsible for ensuring that

labels are legible, completed, and directly affixed to the container. The Vetco licensed

hazardous waste hauler will ensure hazardous waste containers are properly labeled for

transport upon pickup.

How to Label Containers

1. Offices will NOT remove the colored labels, they will ONLY have the accumulation

tag updated by the Stericycle technician.

2. As most containers start collecting waste immediately, all dates should be the day of

your waste pickup.

3. Ensure container is situated so the label is clearly visible.

Empty Container Management

Containers that once held a hazardous material can be disposed of as regular trash or

recycled if it meets the definition of empty per Title 22 CCR § 66261.7 and is completely

empty. A container is deemed “empty” if:

1. For containers that held a material that can be readily poured, all material must be

removed by practicable means, e.g. pouring, pumping and aspirating,

2. For containers that previously held materials that are non-pourable, no hazardous

materials shall remain in the container that can feasibly be removed by physical

methods, e.g. scraping and chipping, and

1. Containers which previously held acute or extremely hazardous waste are

considered empty only if container has been triple-rinsed.


of 13

Any completely empty container can go in the trash or by recycled. Containers not

meeting the RCRA definition of empty must be managed as hazardous waste in the

hazardous waste accumulation area. The non-empty container should be placed into

the appropriate hazardous waste container found in the accumulation area.

Universal Waste

Vetco Offices are considered Conditionally Exempt Small Quantity Generators due to

the small quantity of Universal Waste they generate. Vetco offices and in-store clinics

may generate the following types of universal waste:

1. Universal Waste – Battery(ies)

2. Universal Waste – Lamp(s)

3. Universal Waste - Electronic Device(s)

Universal waste must be segregated and stored in structurally sound, closed containers.

All waste must be appropriately labeled with the words “Universal Waste,” type of

universal waste (i.e. batteries, lamps, etc.) and accumulation start date. Universal waste

must be managed in a way that prevents releases of any waste or component of waste

to the environment and can be accumulated for up to one year from the date the waste

was generated.

Prior to disposal of any electronic device, the Market Manager must obtain approval

from the Vetco Tech Support department.


of 13

SPILL RESPONSE EQUIPMENT AND CLEANUP

Each Vetco Office is equipped with proper personal protective equipment and emergency

response supplies, including:

1. Nitrile gloves

2. Safety glasses and/or goggles

3. Absorbent material

4. Bags (Ziploc)

Hazardous or Non-Hazardous Waste Spills

Only someone from the Vetco or Store Management Team (in the WCs) are authorized to

clean up hazardous waste spills (this does not include feces or urine, all partners can clean

this). Hazardous waste spills may include damaged merchandise or maintenance waste. The

following procedure should be followed in responding to a hazardous waste spill:

1. Cordon off spill

2. Contact Manager or Lead Hazardous Waste Manager for assistance

3. Stand by spill until management arrives

If Vetco partner is trained, the following procedures will be followed:

1. Put on nitrile gloves and safety glasses/goggles

2. Clean spill using spill kit supplies

3. Place original container and spill cleanup material into a resealable bag

4. Place sealed plastic bag into a second plastic bag and seal again

5. Mark the outer liner with the contents using an indelible marker

6. Place the liner containing the original container and spill cleanup material into the

appropriate container


of 13

HAZARDOUS WASTE STORAGE AREA WEEKLY

INSPECTIONS

Federal law (40 CFR § 265.174) requires documentation of regular review of hazardous waste

container storage areas. The hazardous waste container storage area must be inspected

weekly using the Hazardous Waste Storage Area Weekly Inspection Log and is generally

completed by the Lead Hazardous Waste Manager or his/her designee. This form includes

notations for records, name, date, and time of inspection, notation of any repairs and

corrective actions.

At Vetco, hazardous waste storage area inspections are to be performed by the Lead

Hazardous Waste Manager or his/her designee.

Instructions for Completing the Weekly Inspection Log Vetco Office Only

1. Complete the Hazardous Waste Storage Area Weekly Inspection Log once a week (every 7

days)

2. With the clipboard in hand, the Lead Hazardous Waste Manager inspects the hazardous waste

accumulation area for the following:

a. The area is organized, accessible and properly signed.

b. The area is clean and free from spills and leaks.

c. Documents any observations made (e.g. leaks, rusting), and the nature of any repairs or

other remedial action initiated.

d. Waste has not been stored for more than the allowed 180 days.


of 13

3. Sign and date the Weekly Inspection Log.

4. File the Weekly Inspection Log in the Hazardous Waste Program Binder.

5. Inspection logs should be retained for a minimum of three years from the date of the inspection.

Weekly inspections should be retained in the Hazardous Waste Program Binder for one year.

Additional weekly inspection logs should be scanned and emailed to [email protected] for

storage on the server.

HAZARDOUS WASTE PICK-UP PROCESS

The Corporate Environmental,, Health and Safety department has negotiated a waste

contract with a national waste hauler authorized to transport and dispose of hazardous waste.

To meet hazardous waste storage requirements, the waste hauler will be scheduling waste

pickups every in varying intervals depending on the need, but always in time to me the VSQG

requirement of 180 days. As a VSQG there is some flexibility to the length of time that HazWaste

can be store onsite. Most can go no more than 365 days between pickups.

Note: if your accumulation area is overflowing and you need to schedule an additional pickup,

contact the ESH Department at [email protected]

Hazardous Waste Manifest The uniform hazardous waste manifest is used to track shipments of hazardous waste from

Vetco’s facilities to the final treatment, storage, and disposal facility. The uniform hazardous

waste manifest contains information on the type and quantity of waste being transported,

instructions for handling the waste, and signature lines for all parties involved in the transport

process. All hazardous waste generated at Vetco Offices will be shipped offsite for disposal

using a uniform hazardous waste manifest.

mailto:[email protected]

mailto:[email protected]


of 13

Procedure When it is time for your facility’s scheduled waste pickup, the following procedures should

be followed to ensure a successful pickup:

1. The waste hauler will arrive at the Vetco Office and ask for the Manager.

2. The waste vendor will collect the waste, properly package, manifest, and remove it for

transport and proper disposal.

3. At pickup, the waste vendor will complete the hazardous waste manifest and sign on

Vetco’s behalf. Vetco partners should not sign the manifest.

4. File the initial uniform hazardous waste manifest in the Hazardous Waste Program binder

and retain for three years. Any additional documents provided by the waste vendor (e.g.

Land Disposal Restriction Form (LDR)) should be filed with the initial manifest.

5. A copy of the final designated disposal facility signed uniform hazardous waste manifest

will be emailed to the Lead Hazardous Waste Manager at the Vetco Offices from

Corporate SSE. Only certain states (MD, MN, CA, NV) will have their final manifests emailed

to them at the as all final manifests are stored and accessible electronically. File the final

manifest in the Hazardous Waste Program binder and retain for three years.

TRAINING

Vetco Offices and those partners working in the in-store clinics must ensure that all employees

who handle hazardous waste receive the appropriate information and training to protect their

health and the environment. Every employee who will handle or potentially handle hazardous

waste or cleanup a spill must be thoroughly trained.


of 13

At a minimum, all Vetco Partners will receive General Hazardous Waste Awareness Training

within six months of employment. The General Hazardous Waste Awareness Training will cover:

1. Waste Identification

2. Waste Segregation and Staging

3. Spill Response and Cleanup

4. Personal Protective Equipment

Vetco Partners will receive the initial Hazardous Waste General Awareness training within six

months of employment and refreshed annually for all employees. Additional training may be

required due to a change in process or work assignment.

The Lead Hazardous Waste Managers will receive the Hazardous Waste training prior to

assuming Lead responsibilities. The Hazardous Waste training will cover additional topics to

ensure the Lead is properly equipped to manage the hazardous waste accumulation area and

respond to hazardous waste spills. The Lead Hazardous Waste Manager will receive initial

hazardous waste training within six months of employment and refreshed annually thereafter.

Learning and Development in conjunction with the ESH team will ensure all Vetco partners have

received either the General Awareness or Lead Hazardous Waste training annually. Copies of

all hazardous waste training sign-offs will be maintained within Human Resources employee files

for a minimum of 3 years.

RECORDKEEPING

Lead Hazardous Waste Managers will be responsible for maintaining hazardous waste

management compliance documents, including, but not limited to:

1. Uniform Hazardous Waste Manifest

2. Training records

3. Hazardous Waste Storage Area Weekly Inspection Log

4. Hazardous Materials Business Plan

5. Agency Inspection Reports

Records shall be maintained by the Lead Hazardous Waste Manager for a minimum of three

years.

RESOURCES

If you have any questions about potentially hazardous waste or the Hazardous Waste Program,

contact Corporate Environmental, Safety and Health.