The Canadian Chemical Producers' Association Codes of Practice: Hazardous Waste Management

PURPOSE

The member companies of the Canadian Chemical Producers' Association (CCPA) are committed as a condition of membership, to the policy of "Responsible Care". This code governs member company actions in meeting the guiding principles of that policy as they relate to the generation, handling and disposal of hazardous wastes, through all of the life cycle stages of research and development, manufacture, transportation, distribution and the end use and disposal of chemicals and chemical products.

Hazardous waste management encompasses operations related to hazardous waste elimination, reduction, recycling, recovery and reuse; the handling, storage, transportation, treatment, destruction and disposal of hazardous wastes; and closure and care of disposal sites. This code applies to company-owned treatment and disposal sites and public or private co-disposal sites used by member companies.

Practice of this code is intended to result in:

* the protection of people and the environment through the responsible management of hazardous wastes and waste management facilities throughout the entire chemical and chemical product life cycle;
* reduction in the generation of wastes;
* the assurance that the management systems necessary for responsible waste management operations are in place and are functioning effectively;
* public and employee confidence in the management of hazardous wastes as a result of the effectiveness of the above.

GUIDING PRINCIPLES

The guiding principles of this code as they reflect those of the "Statement of Policy on Responsible Care" are:

i) manage hazardous wastes in a manner which protects people and the environment from hazards;
ii) provide customers with information about the hazards and associated risks and sound management of hazardous wastes associated with chemicals and chemical products;
iii) provide information about the hazards and associated risks of hazardous wastes and waste management operations to employees, contractors, other people on site and to those in the community who have an interest;
iv) make Responsible Care an early and integral part of the planning of new or modified chemicals, chemical products, processes, equipment or facilities;
v) apply this code to existing, modified and new chemicals, chemical products, process, equipment and facilities;
vi) know the law and regulations concerning waste management, and meet or exceed them in letter and in spirit;
vii) be sensitive and responsive to community concerns about wastes and their management;
viii) work actively to assist governments in developing public policies, legislation and regulations governing waste management.

Code of Practice

1. General

Each member company shall have written hazardous waste management policies, standards and procedures which apply to all facilities through all life cycle stages of its products. Responsibility shall be clearly defined for generating, implementing, auditing and updating them, and for taking corrective action. These policies, standards, and procedures shall meet or exceed all applicable laws and regulations in letter and in spirit.

Each member company shall classify and manage wastes in accordance with this code when, in the judgement of the member company, they should be considered hazardous even though not legally classified as such.

Each member company shall continually evaluate improvements in existing applied hazardous waste management technology and alternate disposal technology.

Each member company shall participate in the development of improved hazardous waste management technologies and promote the establishment of hazardous waste treatment and disposal facilities.

Each member company is encouraged to apply the intent of this code to the management of non-hazardous waste. Each member company shall work actively, alone or through selected organizations, and, if possible, in consultation with other affected stakeholders, to assist governments in developing public policies, legislation and regulations governing waste management.

If a company cannot bring about changes to its hazardous waste management practices to meet the requirements of this code, it shall discontinue operations which produce the hazardous wastes.

2. Hazardous Waste Avoidance - Material Recovery

The underlying principle of hazardous waste management is to avoid the generation of hazardous waste. Recovering the value of materials is preferred to their classification, treatment and disposal as wastes.

The hazardous waste management system shall:

2.1 require consideration of hazardous waste management needs at the initial stages of product research and development or process design and/or modification (refer to the research & development code of practice);
2.2 continually identify waste sources, evaluate opportunities for hazardous waste elimination and reduction, and hazardous material recycle, recovery or reuse, and take appropriate implementation action.

3. Hazardous Waste Handling, Treatment and Disposal

When hazardous waste avoidance is not practicable, treatment or destruction should be employed to render the remaining waste non-hazardous, as preferred options to disposal. When the hazard cannot be eliminated, the hazardous waste shall be contained in a secure manner and monitored to protect people and the environment.

The hazardous waste management system shall:

3.1 identify, classify and require maintenance of records of the hazardous wastes generated, including volumes, characteristics, method and location of their treatment and/or disposal;
3.2 require that all hazardous wastes are destroyed or otherwise treated and/or disposed in a manner which protects people and the environment from hazards;
3.3 reject as unacceptable, where commercially available means for treatment and/or disposal exist, dilution of hazardous wastes for the sole purpose of rendering them non-hazardous;
3.4 reject as unacceptable the long-term storage of hazardous wastes where commercially available means for their treatment and/or disposal exist;
3.5 require that hazardous wastes which cannot be rendered non-hazardous, are contained in secure landfills or geological formations in a manner which protects people and the environment from hazards;
3.6 ensure that the design, construction, operation and closure of all hazardous waste treatment, handling and disposal facilities conforms to sections 2 through 4 of the manufacturing code of practice; criteria for post closure care shall include methods which consider future land use compatibility with the existence of any closed sites;
3.7 ensure that the transportation of hazardous wastes conforms with the requirements of the transportation code of practice;
3.8 define criteria for the selection and use of hazardous waste management contractors and disposal facilities which are external to the company's operations and conduct periodic assessment;
3.9 require that waste management contractors, both within and outside Canada, have appropriate licenses and permits, and require, with due diligence, that they apply this code to their operations when handling member company wastes;
3.10 maintain a hazard communication program which includes training for employees and any outside agencies or contractors involved in the management of company hazardous wastes;
3.11 include a system for providing information and advice on acceptable hazardous waste management practices consistent with this code to customers and end-users of chemicals and chemical products;
3.12 advocate that all customers apply this code to their operations. Each member shall require, with due diligence, that customers apply this code if special requirements are determined to apply to the management of hazardous wastes associated with the product;
3.13 require periodic assessment of hazardous waste management practices, procedures and facilities to confirm that they remain current and consistent with internal policies and standards and this code.

4. Historical Practices

With respect to past hazardous waste management practices and the need to identify and evaluate all previously used disposal sites, member companies shall:

4.1 develop and maintain records which identify, as completely as practicable, the nature and quantity of hazardous wastes sent to those sites;
4.2 conduct environmental studies to the extent practicable on each site;
4.3 notify appropriate regulatory agencies of any pertinent information collected and the results of any environmental studies conducted;
4.4 co-operate with appropriate government agencies in any required remediation activities.

Hazardous Waste Code of Practice
Typical Elapsed Time from Start

1. Coordinator appointed and aware of code requirements.

3 months

2. Management aware of code requirements.

6 months

3. Management assessment of action and resource needs completed.

12 months

4. Assessment results communicated to those who will be involved in planning and implementing action.

15 months

5. Plans developed.

18 months

6. Plans implemented.

36 months