Page 451 - Solid Waste Analysis and Minimization a Systems Approach

IMPLEMENTATION AND APPROACH 429

■ Employee health and safety
■ Regulatory compliance
■ Releases and discharges to other media

33.5 Implementation and Approach

The implementation of waste minimization in the electronics and semiconductor field
is a four-step process based on the hierarchy of solid waste management:

1 Minimize the generation of wastes as much as feasible.
2 Minimize the hazard of the waste generated as much as feasible.
3 Manage the waste on-site where possible (treatment).
4 Select the off-site disposal technology which reduces the long-term liabilities as
much as possible, first examining recycling options, followed by treatment, incin-
eration, and finally landfill methods as a last resort.

Hazardous wastes are one of the major waste streams generated in this sector. It is
important to ensure that the wastes are handled and disposed of in accordance with all
laws and regulations and that off-site disposers are handling wastes properly and they
present no unnecessary liabilities.
In terms of off-site disposal facilities it is very important that the facility has the
ability, commitment, financial resources, and high level of compliance to handle a com-
pany’s wastes. Steps to accomplish this include

■ Always audit a new facility before sending any wastes to them.
■ Periodically audit existing facilities—changes in ownership.
■ Use an audit check sheet.
■ There are services available that provide audit reports.
■ Comes down to a gut-check level of comfort.
■ Sometimes Toxic Substance Disposal Facilities (TSDF) facilities are not readily
available in local areas or have limited capabilities.
■ Don’t spread out the liability too much. Try to limit to only a few good facilities
with multiple capabilities.
■ Superfund, Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA), clean-up costs, liability—good key words when discussing options
with management.

In regards to source reduction Senate Bill 14 (The Hazardous Waste Source
Reduction and Management Review Act of 1989) requires a source-reduction evalua-
tion review and plan every 4 years. This focuses on wastes that represent 5 percent or
more of the total, including aqueous wastes and manifested wastes. The process
requires a hazardous waste management performance report covering the previous
4 years as well and it must be made available to the public on request.