Sustainability Trends Impacting Retailers in 2014
Definitions of which materials are considered hazardous vary at the federal, state and county levels, and are constantly evolving with political, environmental and economic pressures.
In addition to these challenges, a number of trends are emerging to further complicate the industry and force major retailers to evaluate their environmental compliance programs. In 2014, digitalization, geographic shifts and a need for inventory optimization are developments that retailers will need to consider as they evaluate their approach to hazardous waste management.
While many businesses have already gone digital—take online banking or retail, for example—the EPA is playing catch up. In October 2012, President Obama signed into law the Hazardous Waste Electronic Manifest Establishment Act, which directs that by 2015, the EPA must come up with a uniform plan to move from paper-based to digital documents for all of its records. Referred to as e-Manifest, this national system will extend to all federal- and state-regulated wastes.
The e-Manifest initiative will help waste generators by allowing them to complete manifests online with easy drop-down menus. It will also facilitate the tracking of shipments and provide confirmations that shipments have been received. Lastly it will help reduce the inefficiencies of paper record-keeping by centralizing the data electronically.
As the e-Manifest initiative takes shape, retailers will need to modernize their own compliance reporting environments for the digital era. To get ready for e-Manifest the EPA recommends that retailers:
- Participate in one of EPA’s system requirements meetings or webinars and help EPA to understand data systems used to track hazardous waste and generate manifests.
- Communicate with transporters and treatment storage and disposal facilities since they often supply the technology with which generators will participate in e-Manifest.
- Check the e-Manifest website regularly for new information as it becomes available.
Coastal states have historically been the drivers of compliance because of their proximity to watersheds and coastlines. But this is beginning to change as many landlocked states are now taking hazardous waste regulatory activity more seriously.
In the past, states such as California and Florida have led the charge when it comes to regulating retail hazardous waste disposal. But now, with greater focus from the EPA on a national level, retailers with facilities across the nation must divert their attention to areas not historically considered active sites of regulation.
This geographic shift has significant implications for retailers. Companies that have invested compliance program dollars in states that have been highly regulated historically, will be left scrambling to address these new vulnerable areas.
States that have reportedly stepped up oversight of retail hazardous waste disposal include Minnesota, Kansas and Missouri. Companies with retail locations in these areas must ensure their compliance programs are up to par. Because geographic location can have an impact on regulatory activity, retailers should take stock of their hazardous waste volume to better manage it in a compliant manner. The EPA divides hazardous waste generators into three categories based upon the quantity of waste they produce.
- Large Quantity Generators (LQGs) generate 1,000 kilograms per month or more of hazardous waste, more than 1 kilogram per month of acutely hazardous waste, or more than 100 kilograms per month of acute spill residue or soil.
- Small Quantity Generators (SQGs) generate more than 100 kilograms, but less than 1,000 kilograms, of hazardous waste per month.
- Conditionally Exempt Small Quantity Generators (CESQGs) generate 100 kilograms or less per month of hazardous waste, or 1 kilogram or less per month of acutely hazardous waste, or less than 100 kilograms per month of acute spill residue or soil.
By understanding how much waste is being generated at each retail location, retailers can assess their risk of non-compliance.
In the past it has been enough for retailers to recycle the majority of their waste and contract companies to haul away hazardous materials for proper disposal. But with a greater focus on sustainability and environmental compliance, retailers need a more organized, proactive approach to hazardous waste management.
The EPA requires that retailers understand which of their wastes are hazardous so that the material can be properly managed, reported, tracked and disposed. To start, products deemed unsalable should be kept segregated from salable merchandise. Each unsalable item must then be identified as either 1) returnable to the manufacturer, 2) able to be reused via donation, 3) resold, or 4) as waste. Hazardous waste generally falls into the following six categories: flammables, corrosive acids, corrosive bases, reactives/oxidizers, toxics, and universal non-aerosols. This EPA reference guide provides a full listing.
As more retailers invest in inventory optimization, their compliance programs should be integrated to digitally record hazardous waste as it is segregated, classified and reported. With this approach retailers have access to data about customer returns, expired inventory, overstocked inventory and more. By saving these costs, a compliance program in hazardous waste disposal could deliver a positive impact on the bottom line. For example, a retailer could receive manufacturer credit for expired medication, or order less volume of a seasonal product like sunscreen that may have low sales, but must be treated and discarded as a hazardous material. Retailers can also analyze waste production identify ways to optimize inventory, decrease scrap and potentially receive credit for inventory scrap losses, much like the manufacturer credits received for expired medications.
While there’s no crystal ball to predict the many changes that have an ongoing impact on companies trying to manage their hazardous waste, it can broadly be assumed that sustainability will continue to grow in importance. Taking responsibility for the waste streams produced at retail locations plays a critical role in protecting the environment.
Mike Rozembajgier is vice president at Stericycle ExpertSOLUTIONS where he currently oversees marketing and business development initiatives for the StrongPak service – the leading, comprehensive answer to nationwide retail hazardous waste compliance.
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