Business Objective

ALG was contacted by a food manufacturer and their legal counsel following an inspection by their local CUPA, which identified a number of potential violations of the California Hazardous Waste Control Law and DTSC implementing regulations. Legal counsel directed ALG to perform an audit to verify the compliance status of all operations, to prepare a waste management compliance plan and to provide training to applicable employees. This work was to be accomplished within a compressed period dictated by the CUPA's Notice to Comply.

Technical Approach

Together with legal counsel, ALG staff conducted a thorough site review, including extensive interviews with management and operations staff. ALG's review followed the DTSC inspection guidelines, and confirmed the compliance status of all waste-handling operations. This inspection tool was also used to train for plant staff and resolve misunderstandings relative to waste management requirements unique to California. On-site records were also reviewed to verify hazardous waste generator status and manifest management.

To assure ongoing compliance, ALG developed and trained management and operations staff on a customized Waste Management Plan. This Plan summarized requirements of a Small Quantity Generator (SQG) as applied to our clients operations, including waste determinations for specific waste streams, required waste inspections, manifesting, reporting, and recordkeeping requirements. This customized Compliance Plan translates often complex regulatory jargon into specific tasks, with all roles and responsibilities for staff clearly defined. Inspection tools, in-depth waste management protocols, a filing system, and on-site training was provided, with annual refreshers provided in subsequent years. Notably, the CUPA's follow-up inspection complemented the facility on its thorough and proper management of hazardous wastes.

Results

The project was a turn-around for the facility and its environmental staff. Uncertainties regarding waste management practices were resolved, the thorough and timely response minimized financial exposure, and the follow-up inspections by the local CUPA reinforced that the facility now properly manages all of its hazardous waste streams.