Disposal of Hazardous Products During Cleanup from Flood Damaged Businesses.
My sincere sympathy goes out to all the citizens of South Carolina who have endured the recent storms and flooding. I was living in the Lowcountry during the “Summer of Rain” in 2011 when we saw storms come through and dump rain on our farm every day for 2 months or more. You have seen much more rain than that in the space of just a week or so, and the results speak for themselves; damage and destruction as the people here have never seen before.
Personal and Business Loss
The personal loss is really beyond my comprehension. Home, cars, irreplaceable belongings, animals and even a few loved ones are gone. The business losses are staggering as well: buildings, equipment, inventory, records and data have been washed away. It will take a long time for things to return to normal.
I was contacted last week by a client of mine in Columbia, SC. They were planning to close the facility in 2016, but that has changed. The property was inundated with eight feet of water. The damage was so extensive that they decided not to try to rebuild and have permanently ceased operations. A major part of the closure will be the disposal of a large quantity of damaged hazardous materials that were left behind when the waters receded.
The Recovery Begins
Now that the recovery efforts are underway, businesses all across the state are facing the same problem: how to dispose of their damaged inventory. Some water damaged products can be sold as salvage, some can be loaded into roll offs and brought to landfill, but some unsalable products contain hazardous materials and have special disposal requirements. Even though a state of emergency has been declared, the regulations for the proper disposal of hazardous wastes are still in effect.
Hazardous Retail Products
What makes a waste hazardous? Many common products on the shelves of retail stores contain chemicals that are flammable, corrosive or toxic. Hundreds of consumer commodities in thousands of retail stores are hazardous waste when they must be disposed of, for example:
• Paints that contain solvents like MEK or toluene
• Rust removers that contain phosphoric acid
• Spray paints which have flammable propellants
• Drain cleaners with sulfuric acid
• Batteries of all kinds except alkaline batteries
If the materials in your warehouses or the products in your stores are being disposed of and are also hazardous, you need to contact a company that has the specialized experienced to make the proper arrangements. Don’t let anyone tell you that you can put your chemicals wastes in the trash. It is a federal crime to illegally dispose of hazardous waste and there is no need to add that to the burden of rebuilding your business.
Liquid products are prohibited from direct landfill disposal. These are easier to discard than hazardous products, but must still be handled separately from other solid debris. After they have been solidified, they will be eligible for disposal at regular municipal landfills.
Who to Call?
You will want to get in touch with a company that has integrity. Disasters are always accompanied by quick money scam artists. I recommend you choose a local company that has been in the area for a few years at least. You will also want to deal with people who know what they are doing, preferable those who have had emergency response cleanup experience.
Whoever you contact, they will likely ask three primary questions:
1. What kinds of products do you need to dispose of?, and
2. Do you have MSDS’s for the products?
3. How much do you need to dispose of?
The MSDS is the Material Safety Data Sheet (also called Safety Data Sheets). Hopefully, you have these on hand as part of your OSHA Hazard Communication plan. These sheets will tell the disposal company everything they need to know for the proper packaging, transportation and disposal of the waste. If you can give them an approximate inventory, that will be very helpful.
Chances are, they will not be able to give you a fixed price for the work. Be prepared to accept a Time & Material proposal, because there is likely not enough information to determine all the costs associated with the project.
There are other details to deal with regarding the scope of actions needed to clean up after a disaster, but this is enough to get you started in the right direction.
If you have any questions about how to proceed, I will do my best to answer them without fee. My desire is to be of assistance in this time of need.