Hazardous MaterialsLitigationOnline TrainingStormwater

Are you feeling lucky? Let’s start off with a quick challenge, I would be willing to wager that you couldn’t tell me with absolute certainty that all your dumpsters or waste containers onsite are closed right now. Go ahead and check, I’ll wait…If you can say at a moments notice “Yes, ALL my dumpsters are closed right now.” Then CONGRATULATIONS!!! You’re one of the elite few! You should be saying with pride that your dumpsters are closed!

Now let’s jump right into the dirty stuff, dive in that dumpster! And I’m not really talking about the kind of dumpster diving you did in college to score a banged up coffee table or couch when someone is moving out of a nearby apartment…I know I’m not the only one who’s done that…

1. Why do we have to care about closing our dumpsters anyways?

To quote the California Industrial General Permit (IGP) for Stormwater, “Cover industrial waste disposal containers and industrial material storage containers that contain industrial materials when not in use.” is one of the minimum required Best Management Practices (BMPs) for Material Handling and Waste Management. This is listed as a minimum BMP for good reason too, if you leave an open dumpster out in a rain event can you imagine all the gross juices leaching from the dumpster into your stormwater as the rain washes over the trash?

Fortunately, this is one of the easiest (cheapest, and most effective!) BMPs to put in place. If your dumpster has a lid, close it, if not, get a lid or tarp and close it. Unfortunately, this is the easiest violation for an inspector to spot the moment they walk onsite (Check out the #2 Hazardous Waste Violation listed here). So my advice is to train staff on why they should be closed. You won’t get very far if you’re the only one closing them, but if others understand the need, they should be willing to pitch in too!

2. What stuff should we avoid throwing in our trash?

Well, there’s tons of stuff you should probably think twice about before just throwing it in the dumpster… (Let’s go back to this list and check out #5)

IMG_1070

While most trash removal companies are more than willing to take what you’re throwing out, there are some items of note which are not allowed to be thrown out into dumpsters. Congress enacted the Resource Conservation and Recovery Act (RCRA) in 1976. Reflecting that the unregulated disposal of hazardous waste posed serious threats to human health and the environment, RCRA created a comprehensive regulatory scheme to enable the Environmental Protection Agency (EPA) to monitor hazardous waste along the continuum from cradle to grave. Illegal hazardous waste dumping is an environmental time bomb. While the harm caused by improper hazardous waste disposal may not be immediately apparent, by that time it manifests it may be both irreversible and severe. Common items listed below should never be found in your waste stream:

  • Oil Filters
  • Solvents
  • Paint
  • Aerosol Cans
  • Propane Tanks (Did you know they compact waste?)
  • Motor/Transmission/Lubricating/Hydraulic Oil
  • Anti-freeze
  • Tires
  • Batteries
  • Fluorescent Tubes

You wouldn’t throw toxic waste into a storm drain (or at least I hope not), so do not throw toxic waste into the trash unless you want to set yourself back $16 million. Unsure what’s supposed to be in your trash? Read container labels or the Safety Data Sheet (SDS) for proper use and disposal recommendations.

3. Mixing waste streams! Don’t do it!

Aside from the fines of a Sanitary personnel going on your site and taking pictures of your waste stream because of incompatible wastes and if you’re like the City of San Francisco, who mandated an ordinance requiring all institutions to separate food scraps, recycled material, and trash into three separate containers; fines could be up to $1000. Check out the city of Seattle’s public shaming method too!

All garbage goes somewhere, but it does not go away. Anything that is of potential harm to the environment and/or the person(s) picking it up should not be thrown away. If your hauler was picking up hazardous materials they will need to proper certification and licenses to transport your hazardous materials. Remember not to look at this as an inconvenience, but rather a precautionary measure for both you and the hauler picking it up. Aside from the aforementioned items and RCRA regulations making it illegal to dispose of in your dumpster, these items contain dangerous chemicals that could possibly leak and as a result, catch fire, or expose someone without the proper protective gear to something poisonous or something carrying disease. This can create a serious and urgent problem.

 

Screen Shot 2018-06-11 at 3.54.21 PM

 

4. Monthly inspections of your dumpsters is necessary.

Nearly all dumpsters and trash compactors eventually leak after wear and tear. It is good practice to routinely check your dumpster for any signs of cracks, leaks, corrosion, or deterioration. Especially if your dumpsters have an open top, or the top is left open at times when materials are not being dumped into them, stormwater makes contact and will mix with your trash and leak out to the stormwater discharge conveyances onsite.

IMG_1071

Not to mention after the stormwater gets mixed in with your trash and if you are like Home Depot who was fined for $28 million, things like batteries, aerosol cans, and electronic devices get thrown in the mix and produce a lovely juice for your storm drain.

5. The real Dumpster Divers!

Believe it or not, there are several regulating authorities from city sanitation departments to third-party Non-Government Organizations that will take a deep look into your trash bins! When trash is picked up from your site, the first journey it typically makes is to a transfer station where trash is further sorted. This process makes it fairly easy for one of these transfer stations to determine where some articles of trash are coming from, and they will pay attention to who’s sending them the nasty stuff. A couple pictures of some articles of trash in the wrong bin can easily lead to the grounds for a fine, penalty, or the start of a lawsuit.

The only true test to ensure your own compliance with trash regulation is to dumpster dive yourself! You might want to pull out some bags from the trash and tear them open to see what’s inside, maybe just taking a glance in the dumpster is enough for you, maybe you just don’t want to get too dirty? Remember trash is not sanitary and if you are going full bore in there, make sure to cover up and wear appropriate PPE to avoid getting cut, or something spilled on you. Check out On Dumpster Diving for some motivation!

No matter what challenges you may be facing with your trash or trash disposal, odds are the most effective way to deal with the challenge is through increased staff training and signage. Trash doesn’t throw itself away, so if you find something where it doesn’t belong, you can find someone that’s responsible.