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What Should You Do When Your Hazardous Waste Is Rejected?

A container of hazardous waste in a facility

Introduction:

Rejected hazardous waste shipments trigger a cascade of regulatory, environmental, and operational challenges requiring a swift and informed response. In 2024, the global hazardous waste management market was valued at almost USD 15.7 billion and is forecasted to grow to more than USD 25 billion by 2032. This sheds light on the increased volume and complexity of the global hazardous waste. The stakes are high, and the improper handling and disposal of hazardous waste is a huge threat to the ecosystem and public health and causes costly regulatory penalties and disruptions in general operations. These risks are also underscored by real-world incidents, as in 2022, a toxic gas release at a hazardous waste facility occurred due to misclassified acid waste, leading to fatalities and emergency evacuations. In addition, the United States deals with more than 35 million tons of hazardous waste per year, with stringent classification and transport SOPs preventing accidents and environmental contamination. A rejected shipment of hazardous waste can pose a major compliance and safety risk. Read our recent blog to find out the key steps to follow during rejection to handle the situation efficiently and remain compliant.

Why Was My Hazardous Waste Rejected?

Hazardous waste must be shipped strictly while adhering to the regulations and guidelines, as any misstep can cause rejection. You can avoid delays, fines, and possible environmental hazards by understanding the common causes of hazardous waste rejection.

Common Reasons for Hazardous Waste Rejection

1. Non-Compliance with Regulations:

Non-comppance with particular regulations such as the International Air Transport Association (IATA) Dangerous Goods Regulations, Transport of Dangerous Goods (TDG) Regulations, and the International Maritime Dangerous Goods (IMDG) Code can cause rejected shipments.

2. Unplanned Closure:

An unpredicted breakdown in the equipment or machinery at the consignee's site, without alternative management plans, also causes waste rejections.

3. Planned Closures:

If the consignee shuts down the equipment or machinery for maintenance without informing the customers, the waste arriving at the site might get rejected.

4. Weather Conditions:

Heavy rains and high winds lead to temporary site closures, particularly at the landfills, causing hazardous waste rejection.

5. Incomplete or Incorrect Waste Documentation:

A hazardous waste that arrives at the consignee's site without the proper consignment note will be rejected. Inaccurate or incomplete shipping papers, such as the shipper's declaration of the dangerous goods, also lead to rejection.

What are the Regulatory and Compliance Issues that Lead to Hazardous Waste Rejection?

1. Consignment Note Errors:

The waste must be properly described by the consignor on the consignment note. The consignor is required to properly describe the hazardous waste on the consignment note. If the description is false or incomplete, the consignee cannot certify the consignment and must reject the load. The consignment notes must not be altered by the carriers, and if alterations are suspected, then the consignee should verify the details with the consignor.

2. Non-Compliant Training:

All the shippers and personnel who handle hazardous materials must hold current & relevant training and certification. Non-compliant and expired training causes shipment rejection and possible fines.

3. Regulatory Non-Compliance:

Noncompliance with hazardous waste regulations causes penalties, particularly if the hazardous waste leads to pollution incidents, environmental damage, and injuries.

What are common documentation or packaging errors?

1. Faulty Packaging:

Inadequate or incorrect packaging that is non-compliant with the regulatory standards is a common cause for the rejection of hazardous waste. Hazardous materials must be packed to avert leaks, spills, and harm during transport and should be packed according to the UN performance packaging.

2. Wrong Markings and Labeling:

Improperly labeled and marked hazardous materials can cause rejections. Incorrect labeling includes missing or incorrect hazard labels and improper UN numbers.

3. Incorrect Quantity Limits:

The shipping quantities that surpass the allowed limits for hazardous materials also lead to rejection. That is why it is important to understand quantity limits for different modes of transportation for hazardous waste.

4. Unfit Segregation:

Hazardous materials that are not properly segregated according to their hazardous class may be rejected. Some materials need to be packed and transported separately due to the risk of potentially dangerous reactions.

5. No Consignment Note:

Producers and holders must complete consignment note for all hazardous waste that is moved from their premises except in certain situations. If any waste arrives without the consignment note, the consignee must reject it.

6. Oversized and Overfilled Waste Containers:

Waste containers that are overfilled or oversized also get rejected.

What Immediate Steps Should I Take After Rejection?

If your hazardous waste shipment gets rejected, you should take swift and proper actions to ensure regulatory compliance, safety, and environmental protection. After the rejection of your hazardous waste, you should take the following key steps immediately:

1. Safely Contain and Store the Rejected Waste

After rejection, hazardous waste must be securely contained to prevent any leaks, environmental contamination, and spills. If the waste is present at the storage, treatment, and disposal facility, they should offer secure temporary storage while arrangements are made for another destination or return generator. If the waste is placed at your premises, it should be stored in designated containment areas that comply with regulatory standards for hazardous waste storage. It includes using proper containers, clear labeling to identify waste and related hazards, and secondary containment systems. Incompatible wastes must be properly segregated to avoid chemical reactions and accidents. During this timeline, leaks and other waste hazards must be monitored until the waste is properly treated or transferred.

2. Notifying Relevant Internal Teams and External Partners

On the spot, notify your internal environmental health and safety (EHS) teams, hazardous waste coordinators, and management to start their response. Communicate with all stakeholders so that they completely understand the situation and can deploy the resources effectively. Inform hazardous waste transporters and the rejecting facility about the hazardous waste rejection to clarify the reasons for rejection and discuss the next steps with them. You might also need to coordinate with other TSDFs (Treatment, Storage, and Disposal Facilities) that can accept the waste or return your rejected waste to your facility. The law also abides regulatory agencies to be notified, especially if the rejection contains environmental risks. Keeping documentation of all communications and required actions are needed for both compliance and possible audits.

3. Document the Rejection and Initiate a Corrective Action Plan

After Rejection, it is critical to:

Document the hazardous waste rejection in detail, including the date, time, facility name, rejection reasons, manifest tracking number, and any other related information.
Identify the discrepancies and errors by reviewing the manifest and shipping paperwork.
Look into the causes of the rejection, such as improper packaging, mislabeling, incompatible waste, and regulatory noncompliance.
Begin the corrective actions required to prevent the recurrence of the rejection, including retraining the personnel, improving the labeling and packaging systems, and updating the procedures.
With the help of this step, you can tie together compliance, improvement loop, and learning required for sustainable hazardous waste management.

These immediate steps aid in risk mitigation, ensuring regulatory compliance, and facilitating the efficient and safe management of rejected hazardous waste.

How Can I Resolve the Issues That Led to Rejection?

Resolving the issues that caused the hazardous waste rejection needs a systematic approach to fix the errors, evaluate the waste characteristics, and get expert guidance. All these steps allow for compliance and proper disposal of waste.

1. Correct Packaging, Paperwork and Labeling

Start an in-depth review of all the labeling, documentation, and packaging to pinpoint the discrepancies that caused the rejection. Fix any errors in the waste manifest and ensure correct descriptions, quantities, and hazard classification. Replace and relabel the containers to match the regulatory standards for markings and labeling. If the packaging is insufficient or non-compliant, the waste should be repackaged. Recheck all the paperwork for the physical waste to confirm the accuracy and consistency before you submit the waste for transport.

2. Retest and Reclassify the Waste if Required

If the waste is rejected due to wrong and uncertain waste classification, then a detailed retesting of the waste stream must be performed. Analyze the waste's chemical properties and hazard characteristics by using certified laboratories. This ensures proper classification of hazardous waste by regulatory standards. Then, depending on the new test results, reclassify the waste if required and update all the related documentation to ensure the correct classification.

3. Turn to the Hazardous Waste Disposal Experts or Authorities

Connect with expert hazardous waste disposal personnel or regulatory authorities to resolve complex issues or uncertainties. The experts can help you with insights about the regulatory requirements, help with waste characterization, and suggest a proper disposal method. The authorities can help you clarify the compliance obligations and address concerns about waste handling and disposal. With the help of this collaborative approach, you can ensure all your actions are aligned with the legal and safety standards, fending off future rejections and encouraging responsible waste management.

How Can I Prevent Future Rejections of Hazardous Waste?

To prevent future rejections of hazardous waste shipments, you should implement robust waste management practices that include in-depth training programs and strategic partnerships. All the employees should be properly trained regarding the risks related to hazardous wastes and their proper handling procedures. Make sure all personnel are trained in pre-acceptance procedures and waste rejection protocols. Update the current training and offer regular refresher training to the employees to stay compliant with the regulations and avoid shipment rejections and possible fines. Develop a safety culture by educating the employees on the hazards related to the materials they handle and the need for proper storage techniques.

Make sure the waste is characterized and appropriately reduced through changes in the recycling process and the use of safe materials. Waste must be marked and kept in properly enclosed, compatible containers and separated depending on the hazard class to avoid reactions. Routine inspections, proper zoning, and an understandable emergency plan with a spill kit help ensure safety. Certified waste disposal services can be utilized to allow the proper handling and disposal per the regulations. Enforce rigorous waste acceptance standards, train the employees on pre-acceptance procedures, and use technological applications such as QR codes to monitor waste. A robust supplier program resolves mislabeling, contamination, and quality problems.

The Wrap-Up:

Hazardous waste shipment rejections are not only a logistical setback but a major compliance failure that can cause major health, environmental, and financial consequences. Organizations that routinely audit their hazardous waste procedures, partner with certified disposal services, and retrain their staff significantly reduce their risk of rejection. Remember that each rejected shipment is not simply a missed delivery; it is a red flag about your waste management strategy and system. By confronting those vulnerabilities directly and building regulatory compliance into every phase, from waste classification and packaging to transport and storage, you can safeguard your employees, your community, and your company's reputation.