PRSM 2014 Trends Report - (Page 11)

THE ENVIRO RULES ARE CHANGING Waste Management’s Rodel Urmatan on today’s evolving and increasingly stringent regulatory environment TRENDING: WASTE MANAGEMENT The U.S. Environmental Protection Agency (EPA) reports recent reductions in hazardous waste and other pollution, along with $252 million in civil and criminal penalties levied. EPA also reports the number of water systems with serious violations has declined by more than 60 percent over the past three years as a result of combined federal and state enforcement work. Rodel Urmatan M ulti-million dollar fines, injunctions and increased monitoring for ongoing compliance with environmental regulations are the result of findings against a number of retailers in recent years for mismanagement of hazardous waste. The increased scrutiny and enforcement of regulations in retail facilities is continuing, as key progressive states as well as the U.S. Environmental Protection Agency (EPA) aggressively focus efforts, especially in the areas of hazardous waste management and commercial waste recycling, said Rodel Urmatan, LEED AP, Senior Associate with Waste Management Sustainability Services (WMSS). “The Hazardous Materials Regulations (HMR) is the law, but enforcement, especially in the retail industry, has not been strict,” he said. The push to hold retailers accountable for proper identification, storage, handling and disposal of hazardous materials is appearing first in progressive states such as California, but this is a good time for all facilities managers to review their protocols. Retailers are increasingly placing higher priorities on waste reduction and disposal compliance in search of cost savings and fee avoidance, all part of an overall green and sustainable strategy. In McGraw Hill’s 2013 SmartMarketReport, 62 percent of retailers cited recycling as an important aspect of their green building strategy. Fully 77 percent consider green waste handling practices more important than any other type of green product or practice. Of particular concern for FM is the “reverse logistics” supply chain. As more retailers offer online services to customers, the number of returns shipped back to the store also increases. The National Retail Federation reported that in 2010 the average return rate for online purchases was eight percent. These returns, in addition to items returned “in person” to a store, may now be classified as hazardous materials. “Consumer products that are no longer usable for sale are considered fully regulated by HMR and must comply with all requirements,” he said. For example, nonworking electronics or toys that contain batteries must be shipped back to the manufacturer or distribution center in ways that are consistent with HMR requirements. Unfortunately, improper packaging and labeling is often used by retail employees to return items because they do not realize they are classified “hazardous.” Retailers have been slow to react to requirements but increasing enforcement accentuates the importance of understanding the protocol surrounding hazardous waste management in your store, Urmatan said. “Although the fines have been significant, negative publicity about an organization that operates in an unsafe manner can create more damage to According to the Retail Industry Leaders Association’s second annual Retail Sustainability Report, nearly all surveyed companies have initiatives to reduce waste and increase recycling. Companies reported recycling at stores not only reduces costs, it engages the store employees—some of the sector’s biggest advocates. Over the next two years, the report says, companies will increasingly focus on green building practices, management of greenhouse gas emissions and water use. a business than a monetary fine,” he said. “We live in a social network world, so news that a retailer may have mishandled waste materials and gets fined by a regulatory agency will be reported beyond legal documents and official reports. Consumers will question  if the retailer has other unsafe practices.” Proactive Action Required The first step to ensuring compliance with HMR is to understand the regulations and how they apply to the organization. “Some seemingly innocuous products, such as shampoo or over-the-counter medications, are regulated,” Urmatan said. This means the storage and disposal of outdated shampoo must meet certain guidelines. The next step is to develop a hazardous waste management program or protocol that addresses the specific needs of the retail facility. The plan must address where you store outdated product as well as the timeframe and method of disposal. “Look at storage areas carefully,” Urmatan said. “Not only should they be separate, distinct areas but they should also be located in an area that provides easy access for disposal transport.” Throughout the process of storage and disposal, documentation must identify timeframes, processes used and chain of custody. I 2013 I 11

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PRSM 2014 Trends Report