Hazardous Waste Management For Trucking and Logistics Companies

Whether in garages or on the road, trucking and logistics firms will episodically require hazardous waste management to deal with uncontrolled releases. Q&As in this entry include:

1. Why & how is hazardous waste management important to trucking/logistics companies?
2. How should you deal with an accidental release of hazmat in a trucking garage?
3. What should a spill-emergency response plan include?
4. Who should be in charge of your spill-emergency response plan?
5. How extensive should your spill-emergency response plan be?
6. How should you deal with an accidental fluid release on a roadway?
7. When should you not try to clean up a garage or roadway spill?
8. Where can you get advice & help about managing garage or roadway hazmat spills?

1. Why & how is hazardous waste management important to trucking/logistics companies?

Although you might not be transporting hazardous material per se, and even though hazmat transport is not part of your business, you face the possibility of an uncontrolled release of material considered RCRA hazardous.

This is because an unplanned uncontrolled release of too much of anything into the environment can be considered a hazmat spill, no matter how benign that material might be under controlled circumstances.

Our favorite example is milk.

The typical tanker truck used in the dairy industry carries anywhere from five‑to‑eight thousand gallons of milk (see source). And although moo-juice seems to be the furthest thing from a hazardous material that one could imagine, a slick made of five‑to‑eight thousand gallons of milkfat will choke off a waterbody just as effectively as one made of escaped motor oil.

All that milk will also decompose. Decomposition requires oxygen. Different substances consume more or less oxygen than do others. The metric for this is called Biochemical Oxygen Demand (BOD). Too much high-BOD waste can create an oxygen shortage that kills aquatic life: from microorganisms to fishes.

And the EPA will not be amused.

In a perverse sense, a spill of material that’s patently RCRA hazardous (like motor oil) can wind up being easier to cope with than one that’s seemingly benign (like milk). This is because generators are required to mark or label RCRA hazmat, which is done (in part) to inform drivers about what procedures to follow and precautions to take for the particular kind of hazmat they’re hauling.

[Factoid: State-by-state protocols for dealing with spilt milk are almost identical for that of motor oil (see source)].

2. How should you deal with an accidental release of hazmat in a trucking garage?

You need to decide now what to do in the event of a spill emergency. The onset of a spill isn’t the time to begin a discussion about what you should do in the event of one. Instead, a spill should instigate a well-defined and rehearsed spill-emergency response plan, with all employees knowing what triggers its implementation. (See Q.4) But in general:

• Alert any nearby personnel so that they can take necessary precautions for their safety and/or evacuate.
• Evaluate the risk by identifying the kind, amount, and relative toxicity of the spilled material. Doing so is the first step for determining whether you can manage the spill yourself or if you require professional hazmat assistance.
• Don the appropriate PPE to safeguard yourself against contamination. Such PPE should be in a spill kit that’s in a clearly marked location. (E.g., boots, eyewear, gloves, hazmat suits, respirators, etc.)
• Follow an approved decontamination plan specific to the type of substance involved if you or someone else has suffered exposure.
• Look for the source of the spill and do your best to stop or at least contain it. (E.g., plugging a hole, up-righting a container, or stopping a pipe flow.)
• Block nearby drains. Dam and divert the hazmat to contain it to a single area.
• Clean and sanitize the contaminated area by using neutralizing agents on any acids or bases present in it. Use pads, pillows, and other absorbents to remove the hazmat. Then sanitize the area with mild detergent. Contain contaminated objects in a safe area until they can be cleansed.
• Contact a hazardous waste management company to discard the hazmat-contaminated absorbents.
• Report the accident per CERCLA requirements.

3. What should a spill-emergency response plan include?

Effective spill-emergency response plans differ across companies according to the types and quantities of materials they handle and the kinds of operations endemic to their enterprise. You can get expert advice here. But in general, a spill-emergency response plan should have five elements:

1. Rescue. Evacuate the spill area, aid affected individuals, and seek emergency medical assistance.
2. Confine. Confine the spill area as best you can. Isolate contaminated people. Don’t allow them to leave and contaminate others. Cover drains to prevent spills from entering municipal sewers.
3. Report. Immediately report the spill to the appropriate emergency response authority, including location, injuries, as well as type and quantity of spilled hazmat.
4. Secure. Ensure nobody enters the spill area until emergency personnel deem it safe. If the area has multiple entrances, locate staff at each to prevent entry.
5. Cleaning. Cleanup must be conducted by personnel who have appropriate training, protective equipment, and cleaning materials.

4. Who should be in charge of your spill-emergency response plan?

A hazmat spill has no regard for your organizational chart. Thus, who should be in charge during a spill emergency might not be the person who’s running things during a normal day.

Thus, it’s important to develop an Incident Command System, wherein once the spill emergency is declared, authority and responsibilities are clear, unequivocal, and without regard to the usual departmental boundaries.

Your plan should map out exactly what must be done during the first hours, days, and weeks of a spill, with responsibilities delegated to specific personnel at each juncture to ensure no important detail is inadvertently neglected that might later become a legal liability.

5. How extensive should your spill-emergency response plan be?

Each step of your spill-emergency response plan should be stated in simple language and well-rehearsed. During an emergency, adrenaline kicks in while “executive functioning” checks out. That means that personnel won’t be in the right state of mind to read and evaluate pages of instructional do’s & don’ts, but they can effectively execute simple, well-rehearsed assignments.

Ensure all your personnel are aware of your spill-emergency response plan and that each knows his or her role within it. Provide regular training to educate new employees and keep current ones qualified. And run drills—some planned and some a surprise—to improve your spill-emergency response plan and assess employee readiness to implement it quickly.

Printed copies of your spill-emergency response plan should be kept offsite as well as onsite in places that are intuitive and easily accessible to employees. Web copies are best kept in a secure cloud-based platform and accessible from virtually anywhere on any device.

6. How should you deal with an accidental fluid release on a roadway?

Protocols differ from state to state. But generally:

You’re accountable for vehicle fluid spillage, including the removal and proper disposal of absorbents (see below) and, if necessary, subsequent site remediation. If you haven’t the wherewithal to do this, the local authority (state, county, city, etc.) will do what’s necessary and send you the bill. That said…

The preferred method for cleaning up roadway fluid spills is to soak up as much of the material as possible using absorbents (e.g., granular materials, vermiculite, floor sweep, peat moss, pads and booms, clay, or topsoil).

Such absorbents should be moved out of travel lanes and onto the shoulder. If possible, the material should be containerized and placed into the damaged vehicle for removal by a towing company.

Absorbents should be put into heavy-duty trash bags, wrapped in plastic sheeting, or placed into buckets or barrels. Each should be tagged and clearly marked to indicate what type of absorbent it is and the material that was spilled.

Such containers should be placed well off the roadway and onto the shoulder where they can remain for a reasonable time to allow for disposal by you or whomever you hire to do so.

Bear in mind that absorbents can leave a thin film on the roadway, making it slippery and commensurately hazardous. In such situations, sand or a light dusting of Portland cement can be used to increase friction. (See source.)

7. When should you not try to clean up a garage or roadway spill?

You should engage a reputable hazardous waste management company for any garage or roadway spill that involves a RCRA hazardous material (e.g., cyanides, bromines, hydrazine, nitriles, etc.). Ditto if you’re unsure whether or not you’re dealing with a RCRA hazardous material.

8. Where can you get advice & help about managing garage or roadway hazmat spills?

Whether in your garage or on the road, a suitable spill-emergency response plan for contending with possible accidents and disaster scenarios is your first defense against the financial, legal, and political damage caused by any hazmat spill. And you can get expert advice about developing your spill-emergency response plan here.

While it might not be possible to foretell how a spill will impact your business exactly, you can nonetheless develop a spill-emergency response plan that will lessen the degree of damage to your operations, your reputation, and—ultimately—your finances.

As in all things concerning hazardous materials, the experience, knowledge, and technical resources of a reputable hazmat management company are essential to keeping you safe and legal.

Contact us about developing your spill-emergency response plan here. Or Call (425) 414-3485.

And thank you for reading our blog!