Going from LQG/SQG Haz Generator to Conditionally Exempt... how did you do it?

Discussion in 'Solvent, Chemical and Haz Waste Best Practices' started by Andy, Aug 21, 2013.

  1. Andy

    Andy Administrator Waste Min Publisher 2013 Industrial Waste Survey Participant

    I tend to shake my head when I hear those outside industry (ie commentators/talking heads) make it seem as if we have a love affair with HAZ materials... that plants WANT to keep these materials around for some reason. And that what plants should do is just "use less hazardous stuff." Simple, huh?

    We all know the reality is much, much more complex... at this point IF there are HAZ materials still used or generated within a plant, chances are that they are core components of manufacturing processes or outputs... so tracking down all of the ripple effects and changes needed to change over to a non-HAZ option is a significant effort.

    If you have gone from large quantity generator (LQG) to small quantity generator (SQG), what did the experience look like for you? How long did it take, how many processes did it involve? Was it one major process/waste stream, or a combination?
    Last edited: Sep 13, 2013
  2. RexB

    RexB Manager, Environmental & Safety - CSP Registered Member

    I wish our experience was sexier, but honestly we went from a small quantity generator to conditionally exempt mainly because we incorrectly classified our waste generation and disposal many years ago. There have been efforts on waste minimization since then but most of it has been geared toward getting some employees to resist letting chemical distributors drop off a drum for the folks to "try".
  3. Andy

    Andy Administrator Waste Min Publisher 2013 Industrial Waste Survey Participant

    That's very interesting on both counts... I can imagine a few "sample" visits could definitely add up over time. In case they're interested, we had the top 15 degreasers lab-tested to find the winner... the hope there is that if people could see the performance of the degreasers, it might help in chemical substitution efforts... and helping to avoid having gallons of the "new" degreasers laying around all over the place.

    http://www.wastemin.com/discuss/ind...ratings-how-the-top-15-degreasers-stack-up.6/

    Any areas of emphasis for waste minimization effort, or just a general push?
  4. RexB

    RexB Manager, Environmental & Safety - CSP Registered Member

    I saw the degreaser info yesterday. Very cool! Nice work! And, yes, it's just a general push. I want people to be thinking outside of the box and coming up with opportunities on their own.