For years, an environmental director at a large regional supermarket chain had little success gaining approval for a waste compliance program. However, that all changed when the company began experiencing pressure from a state regulatory agency. Soon thereafter, as a result of their vast experience in hazardous waste management and strong customer service, US Ecology was retained to provide a standardized waste management program that would grow to cover all of the company’s 200 stores.
In 2009, a large regional supermarket chain issued an RFP to select a provider for a retail waste management pilot program. The company’s environmental director had been pushing for a formalized waste management program for some time, but had found little support internally due to budget constraints and the lack of understanding for a required hazardous waste compliance program. When the director retired in 2010, progress on this initiative was delayed, and it seemed as though hopes of a hazardous waste management program might depart with the director. When the supermarket chain began experiencing regulatory pressure after an inspector took note of deficiencies in hazardous waste handling, however, the company began seeking an experienced waste management partner in earnest to avoid damage to the company’s brand reputation.
It was at this point that US Ecology was engaged. While the two companies had been in contact in the past, it was now clear to the supermarket chain that a hazardous waste compliance program was necessary, and US Ecology had the expertise needed to achieve success.
While the objectives of safely categorizing waste streams and disposing of hazardous waste in a compliant manner were relatively straightforward, there were a number of challenges the waste management team needed to overcome:
- Standardization – Uniformity across all 200 stores was desired at the corporate level to maintain safety and compliance, which required the proper understanding of hazardous waste types and generation amounts to identify the correct collection containers, labeling and waste handling processes.
- Space constraints had to be addressed at each store – Back rooms were used for inventory storage, and space had to be cleared to house bins for different waste streams generated at the store level.
- Training was required for many workers in high-turnover positions – A “train the trainer” model was necessary, where US Ecology would arm trainers with the information and collateral needed to teach non-specialized personnel across all stores.
- Certain parts of the store required their own waste management processes – Pharmacies and fuel stations operated by the supermarket chain were unique operations, with different waste streams that had to be identified, categorized, handled, labeled, and properly stored.
- High volume of products to be categorized for waste streams – With more than 30,000 products (in addition to pharmacy and fuel station products) sold by the supermarket, significant effort was required simply to categorize products into appropriate waste streams for safe and compliant storage and handling.
US Ecology immediately set to work engaging key stakeholders responsible for program implementation and liaisons to store operations groups to clearly develop the steps and tasks that would go into putting in place a comprehensive waste management program. The team worked to define different waste streams and began creating programs to identify, containerize, and safely consolidate waste streams for transportation.
The first step was to identify all of the regulations governing disposal of waste, whether it originated in-store, from returns/recalls or otherwise. US Ecology provided in-depth insights on the Environmental Protection Agency’s (EPA’s) regulation of hazardous wastes, such as those governed by the Resource Conservation and Recovery Act (RCRA), state-level regulations from the five states in which the supermarket operated, and best practices for minimizing waste generation overall. US Ecology explained the various rules and reporting requirements, and educated customer stakeholders on how to comply to develop the best operational program for the customer.
Training and Materials
US Ecology put a training program in place that started with face-to-face training sessions with supermarket personnel who would then use the train-the-trainer model in their stores. Attendees were armed with presentations and physical training documents to allow them to effectively teach other retail associates, inventory personnel, claims representatives, and others, how to properly manage waste at each store location.
Physical containers were also provided for each store, making it simpler for employees to ensure waste was grouped in a compatible manner on site. Compliance kits included labels, posters, signage, and various types of containers.
US Ecology worked with the customer to determine an appropriate service schedule for the various stores’ containerized waste. Adhering to both EPA and U.S. Department of Transportation (USDOT) regulations, US Ecology transports over 30 different waste streams over the public roadways ensuring the waste is properly delivered to a permitted facility. US Ecology worked with the customer to identify the appropriate schedule to meet regulatory compliance rules and operational requirements associated with collection space limitation. US Ecology representatives communicated closely with the customer, ensuring all expectations were met and responding flexibly in the case of off-schedule pickups or last-minute service changes.
Every aspect of the regulated waste management program, including waste streams, weights, dates of service and paperwork, was carefully tracked and recorded. US Ecology provided the data and reports needed to comply with all applicable state and federal regulations. In addition, US Ecology provided information on how to better achieve internal waste reduction and management goals. As required by law, US Ecology kept records of the company’s waste management data on their systems, effectively warehousing the information to prevent data loss.
US Ecology experts worked closely with the supermarket’s environmental and compliance team every step of the way, ensuring direct lines of communication and a dedicated customer service approach to drive the success of the waste management program. In fact, a US Ecology expert now works full time at the customer’s headquarters as a dedicated program manager, showcasing the importance of collaboration in achieving strong long-term results.
Through careful planning and execution, the new waste compliance program has been rolled out to all 200 of the supermarket’s locations. The supermarket chain’s executive team now has far more peace of mind when inspectors visit stores, feeling confident that they can avoid both fines and bad press while protecting their employees and customers. There have not been any Notices of Violation since US Ecology began working with the supermarket chain as a single-source waste management service provider more than five years ago. They have found a trusted partner in US Ecology, helping to protect their brand and bottom line.
For information on US Ecology’s retail waste management solutions, call (800) 592-5489.