• Cradle to Grave Liability: Hazardous Waste Disposal
  • Karen

    Karen D. Hamel CSP, CET, WACH, is a regulatory compliance professional, trainer and technical writer for New Pig. She has more than 25 years of experience helping EHS professionals find solutions to meet EPA, OSHA and DOT regulations and has had more than 200 articles published on a variety of EHS topics. Karen is a Certified Safety Professional (CSP), Certified Environmental health and Safety Trainer (CET), Walkway Auditor Certificate Holder (WACH), OSHA-Authorized Outreach Trainer for General Industry, Community Emergency Response Team (CERT) trainer and hazmat technician. She serves on the Blair County, PA LEPC. Her specialties include a wide variety of environmental, safety, emergency response, risk management, DOT and NIMS topics. She conducts trainings and seminars at national conferences and webinars for several national organizations. She can be reached at 1-800-HOT-HOGS (468-4647) or by email karenea@newpig.com.

  • Shaylee Packersays:
    12/26/2019 at 9:34 am Reply

    I had no idea that not only are you responsible for how hazardous waste was disposed of, but what happens to it 20-120 years down the road. What happens if the regulations for disposing of the waste changes? Are people required to then go and attempt to figure out how to have their old waste fit the new requirements?

    • Isabella Andersensays:
      01/13/2020 at 12:50 pm Reply

      Hi there, thanks for your question!

      They are not required to or figure out how to make it meet the new requirements, per-se; but they are still responsible for it. Cradle-to-grave liability is very encompassing, and it means just that: you are responsible for your hazardous waste from the time it is created and for as long as it exists – even if it was legally disposed of. This can cause problems for facilities 20 or 50 years down the road because your liability doesn’t end with disposal.

      Remember that many of the hazardous waste disposal rules didn’t become effective until the 1980’s or later. For companies that had been “legally” been disposing of hazardous wastes in landfills (due to a lack of any regulations) for decades before the rules became effective, that waste is still their responsibility. If the hazardous waste in a landfill can be tracked back to them, they are still responsible for it and will have to share in the cost of cleaning up the landfill if it leaks or presents an environmental hazard.

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