Issue link: https://read.dmtmag.com/i/670021
w w w. v w m m e d i a . c o m M a y - J u n e 2 016 | V I N E YA R D & W I N E RY M A N A G E M E N T 6 1 like a residential waste generator to eliminate paperwork. They may be able to use a county hazardous waste collection point, for example, in lieu of using a hauler that requires a detailed disposal manifest. STATE OR FEDERAL? With so many state and federal laws addressing hazardous wastes, where do you start? Judy Parker, whose legal practice in Oregon and Washington state focuses on the wine industry, says, "You have to make sure you cover your bases for both state and federal laws, which can be different from each other in ways you might not anticipate." She and others note many states — most notably, California — have environmental laws that are tough- er than those of the federal gov- ernment. In some instances, for example, state hazardous chemical labeling requirements may copy the federal guidelines to the letter, but then add other requirements. For this reason, Beltrame says, start by consulting the website of the state environmental agency or department of environmental quality equivalent. you're doing with the waste before you do it." If you don't yet have a hazardous waste plan, the first step in creat- ing one is to take a comprehensive inventory of waste streams and products in your operation. This starts with knowing what consti- tutes a hazardous waste. There are any number of resources, including textbooks, available to winery own- ers. It's also important to know the volume of these wastes. As men- tioned previously, some states' regulations — including those of the Commonwealth of Virginia — are based on the size of the waste stream generated per month. Part of developing that plan is creating a thorough system one or more people can use to regularly check that all hazardous items are properly stored, labeled and inven- toried. This includes making certain any safety data sheets (SDS, for- merly MSDS) for products onsite Applicable laws and documents should be available as well as links to other agencies with oversight. MAKE A PLAN "One easy way to craft such a plan is at the beginning of your winery construction," says Parker. A form required in the process is the U.S. Department of the Trea- sury Alcohol and Tobacco Tax and Trade Bureau, Supplemental Infor- mation on Water (Form 5000.30) at www.ttb.gov/forms/f500030.pdf. It asks the applicant to: "Describe the methods and means used or to be used to monitor the quality and characteristics of the discharge and the operation of equipment or facilities employed in the treatment or control of wastes or other efflu- ents." Says Parker, "Answering that question now — before you begin to harvest, sort, ferment or rack — can help keep track of what Attorney Judy Parker advises covering your bases regarding both state and federal laws. [Photo by Jim Fischer] Letina tanks, sanitary valves and fittings. St. Patrick's of Texas • StPats.com 50,000 square feet of Stainless Steel