The decision to send your hazardous secondary materials to an off-site recycling business should be followed by a careful review of the qualifications of available recyclers.
There appear to be concerns among regulatory agencies that some recyclers of hazardous materials are not handling the materials they receive in a responsible manner. Improper management can increase liability of the originating company.
EPA recommends that managers investigating recycling opportunities ask candidate businesses some basic questions. For example:
- Ask for a general description of the business, including a point of contact, number of employees, years in business and ownership history, site information and history, summary of operations, and services offered.
- What is the facility’s record of compliance with federal and state regulations?
- Does the recycler normally accept the materials you want recycled?
- Can the recycler describe the processes and procedures for recycling, reuse, or resale?
- Is there a reliable market for the salable products?
- Are any residuals from the recycling process managed in a manner that is protective of human health and the environment?
- Can the recycler provide names and locations of businesses, landfills, or incinerators to which it sends products and/or residuals?
- Does the recycler maintain appropriate environmental liability insurance and are mechanisms in place to ensure cleanup costs would be covered if the facility unexpectedly closes or has to perform an environmental cleanup?
In addition, obtaining references should be part of any business transaction of this type.
EPA has published a short brochure, Choosing a Responsible Recycler, available here.