Off-site Waste Disposal Continues to Create Liabilities

This week, two attempts at waste disposal beyond the borders of the US resulted in enforcement and made headlines, highlighting the need for companies to understand how their wastes are managed by vendors.

In one case, EPA announced that The Hong Kong Environmental Protection Department intercepted a shipment of over 500 computer monitors that had been sent for disposal in China from two US companies.  The waste was shipped back to the companies, who must properly manage the CRTs as well as comply with other requirements of the enforecement actions.

Another case involves waste generated in the UK that was intercepted by Brazilian authorities.  Over 80 shipping containers were found to contain batteries, computer parts, cleaning product containers, baby diapers, food remains and medical waste, among other items.  The wastes are being shipped back to the UK for proper management.

While these instances are public, others may not catch the attention of the media.  Elm recently assisted one client who was the subject of EPA enforcement related to a waste disposal contractor’s unauthorized disposal of hazardous waste generated at one of the client’s manufacturing locations.  That case demonstrated that the contractor had committed fraud and dumped hazardous waste drums on abandoned property.

In economic conditions that are pushing cost reductions to the limits – and costing jobs/salary reductions – inappropriate waste disposal decisions are a possibility within an organization.  Maintaining a strong waste management program and disposal vendor review can be a simple yet powerful tool in significantly reducing off-site waste disposal liabilities.

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