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32 (127) 2017
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Energy & Environment

Due diligence for waste management from manufacturing

Randy Michael Mott, director for Europe, Africa and the Middle East CHWMEG Inc.
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Waste handled by third parties off-site may be one of the biggest supply-chain threats to a manufacturer.

Hazardous waste in the wrong place can end up becoming a major public relations problem; scenes of improper waste disposal are routine in the media now even in Poland. The source of the waste is one of the first journalistic and regulatory responses. Now, under EU waste law, a waste producer is generally considered legally responsible for their waste even if it has been entrusted to a licensed third party. Improper management can give rise to claims for the clean-up and to third-party claims for damages. Integrated pollution-control permits always contain terms that require manufacturing waste to be properly managed to not damage the environment or public health.

The risks of improper waste management welcome even more significant when one looks at the EU regulatory ability to limit these risks. A recent European Commission study found the gap between hazardous wastes that the EU is reported to generate and the volume that is actually recorded as being legally managed is 28%. Some of this gap is statistical error, but it also includes a huge amount of waste misdirected to improper locations. Outside of Naples, authorities have found two million tons of hazardous waste mixed with household waste and dumped by the roadsides.

A roadside waste pile outside of Naples (Washington Post)

Regulatory officials contend that most of it comes from northern Europe. Epidemiological data shows a high rate of serious diseases in the local population. This situation is no longer unusual in Europe or Poland as the cost of proper waste management rises and creates a lucrative market for illegal dumping. Waste facilities can also go bankrupt and leave the customers with the liability.

To deal with this growing problem, many manufacturers have developed programmes to audit their waste vendors.  A periodic review of the facilities that they use provides a wealth of information that can be evaluated to reduce the risk of these problems. Factors including the sensitivity of the location, the design of the facility, its regulatory history,  its financial viability, its operating history and any known releases to the environment provide a reasonable framework to predict which sites can be long-term problems. Many of these factors are not covered by a simple inquiry into the site’s legality. We have also found that various environmental management system certifications are a poor predictor of long-term proper waste management by vendors.

Thousands of these reviews or audits are done of waste vendors every year. CHWMEG itself now does about 350 of these worldwide every year. Our reviews are on a shared-cost basis and are often described as the most thorough audits that the facilities have experienced. The modest cost of a review programme has to be compared to the serious PR, legal, financial  and regulatory exposures associated with ignoring this issue. Because the regulatory system now does a poor job of tracking the waste beyond the first off-site location, we also recommend companies use a contract form that requires their vendors to list the additional subcontractors that they will use for ultimate disposition of the waste.

This function is normally assigned to the corporate environmental health and safety team working in conjunction with the procurement people. The cheapest option for waste management is usually not the safest or the long-term lowest financial risk. Stewardship of your own manufacturing wastes is an important part of your company’s environmental programme and corporate social responsibility.  

 

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