Cradle to Grave: The Most Important Concept for Generators

Most generators understand that hazardous waste is a serious threat to human health and the environment alike. They’re also likely aware that when disposing any hazardous material, they have to contact a waste disposal company to do so properly. What some generators may not know, however, is that generator responsibility goes further than that. As a generator, you’re responsible for your waste from cradle to grave.

First, let’s take a look at the concept itself.

From Cradle to Grave, You’re Responsible

The Resource Conservation and Recovery Act of 1976 was created to combat the alarming fact that, prior to it, only 10 percent of hazardous waste material was being managed in proper fashion.

One of the most notable sections of the statute is defined in Subtitle C. This section established a federal program to manage hazardous waste from cradle to grave, in turn ensuring that hazardous waste is handled in a way that protects both the environment and human health.

But what exactly does cradle to grave mean?

Cradle to grave states that a generator is responsible for its waste from generation to ultimate disposal. Nothing will relinquish a generator of this responsibility—there’s no expiration date or time limit—and hiring a someone else to transport and dispose of your waste does not transfer responsibility.

That’s why we—and any reputable disposal company—stress the importance of staying in compliance and doing things by the book. If an incident happens to occur at any point during your waste’s lifecycle, you can be held liable. It’s possible you may also be obligated to pay some, or all, costs associated with a response or a cleanup.

Given these pieces of information, cradle to grave is arguably the most important concept of RCRA and one you should be very familiar with.

How We Help You When It Comes to Compliance

It’s obviously important to understand cradle to grave and understand that you’re responsible for your waste from beginning to end, but we can make that process easier for you from a compliance standpoint.

Here’s what we’ll do for you:

• Classify your material according to Environmental Protection Agency (EPA) and Department of Transportation (DOT) regulations. Upon doing so, we will draft Uniform Hazardous Waste Manifests (UHWM) for your hazardous waste, along with what is known as a waste profile. The UHWM contains the material’s DOT shipping name, applicable EPA waste codes, your facility’s EPA identification number, weights and measurements, waste transporter’s name, and the name and phone number of the designated disposal facility.

• Create your waste profile. The waste profile is more specific than the UHWM and it contains the waste’s analytical information, including: waste material ingredients, concentrations, viscosity (solid, liquid, sludge, etc.), and BTU value, among other things. It will help identify the hazardous characteristics of waste, such as flammability, toxicity, corrosivity, or reactivity. The waste profile needs to be specific because it will be used by the designated disposal facility to process and dispose of the waste according to EPA standards.

• UHWM and waste profile copies will be given to you after the material has been loaded onto our truck. Roughly 30 to 60 days later you will receive a Certificate of Destruction, which is documentary proof that your material has been legally disposed. Per the EPA, you need to keep these documents in your records for three years. Hazardous Waste Experts will also retain these documents digitally for you should you lose them. It’s important to have these documents if the EPA comes to your facility with questions in regards to how the waste was handled because you would have physical documentation to reference.

• Due to the cradle-to-grave provision within RCRA, we cannot legally take ownership of your waste. However, we can add you to our environmental liability insurance, meaning that should any unforeseen incident occur, you will be insured.

It’s understandable that learning the ins and outs of RCRA can be time consuming and may not be the most straightforward. But if you’re a generator, it’s vital that you take the time to do so. Not only will it help you get a better understanding of your waste and generator status, it will also help you stay in compliance and avoid significant fines and legal trouble.