Issue link: https://read.dmtmag.com/i/205815
Protect Your Business and the Environment – Don't Be A Polluter Recycling as much as possible is a good beginning to EPA compliance. BY ERIC STILES A well-known equipment dealership – which had operated on the same property since the 1950s – received a surprise visit by the local authorities after a waterway located adjacent to the property appeared to have been recently contaminated with an unknown substance. A detailed facility inspection revealed that an uncontrolled storage area located out in the open at the back of the property was the source of pollution. Numerous steel drums and plastic totes of waste oil, gas, and other chemicals had been left unattended and unmarked, and had been leaking contents into the ground for years. A federal agency was called in to begin a site assessment and cleanup. The dealer had little documentation of any waste disposal procedures or training and was left to pay more than $400,000 in cleanup costs and fines. Equipment dealerships have a variety of processes that can generate waste products, including oil and brake service, parts degreasing, battery service, painting and vehicle fueling. Many of these byproducts can be classified as hazardous and are regulated by federal and state agencies, which means your dealership has an obligation to collect, recycle, or dispose of the waste by using a licensed hauler with expertise in local, state, and federal regulations. A lack of pollution-prevention measures can lead to environmental damage, cleanup costs, fines and unwanted media attention. Let's take a look at ways your dealership can help control pollution exposures and maintain compliance with regulatory laws. Does My Dealership Generate Hazardous Waste? Most equipment dealers will generate some level of 18 | www.cedmag.com | Construction Equipment Distribution | November 2013 regulated wastes, even if it's in small quantities. There are two reasons for a waste to be considered hazardous. First, it can be specifically listed as hazardous by the EPA. There are more than 400 wastes listed by their chemical names in Part 261 of the EPA regulations. Second, if the waste does not appear on the list but it has the following characteristics, it can be considered hazardous: Flammables or combustibles, including solvents, degreasers, and paint waste such as thinner or sludge Corrosive products like battery acid, paint stripper, and other cleaving agents Unstable or reactive chemicals including bleaches or other oxidizers Toxic substances with high concentrations of heavy metals including lead, chromium, or mercury Some examples of substances used by dealerships that could lead to the generation of hazardous wastes include lube oil, grease, transmission and brake fluid, antifreeze, Freon, parts cleaner, paint-related materials, and fuels such as gasoline and diesel. Bottom line – it's the dealer's responsibility to identify the hazardous wastes in their operations. And if you are unsure about what to do with it, call a professional disposal service for assistance. We Have Hazardous Waste – Now What? After you have identified your hazardous wastes, the next step is to determine if you're meeting EPA or state recordkeeping requirements. Regulations require all hazardous waste generators to obtain an EPA identification number, regardless of how much waste is generated.