The Challenge
The client generated multiple hazardous waste streams and regularly shipped those wastes to treatment, storage, and disposal facilities. While the company had established waste management procedures, management wanted an independent assessment to verify that hazardous waste transportation activities were being conducted in accordance with applicable DOT and EPA requirements. Leadership recognized that hazardous waste shipments often involve overlapping regulatory obligations, creating opportunities for confusion regarding classification, packaging, marking, labeling, manifest preparation, employee responsibilities, and recordkeeping requirements. The organization wanted greater confidence that its procedures would support continued compliance while reducing the likelihood of violations, shipment delays, or enforcement actions.
STARS’ Assessment Process
STARS conducted a comprehensive review of hazardous waste transportation activities, including waste characterization practices, manifest preparation, shipping documentation, employee training records, packaging procedures, and compliance management systems. The assessment evaluated how DOT hazardous materials transportation requirements and EPA hazardous waste regulations interacted within the client's operation. The review also examined employee responsibilities, management oversight, documentation controls, and verification processes used to support hazardous waste shipments.
Key Findings
- Hazardous waste transportation procedures were generally effective but could benefit from greater standardization.
- Opportunities existed to improve documentation supporting waste classifications and shipping decisions.
- Employee responsibilities were understood but not always formally documented.
- Certain manifest preparation and record retention processes could be strengthened.
- Additional verification processes would reduce the likelihood of documentation errors.
Corrective Actions
STARS developed recommendations focused on improving consistency, accountability, and documentation controls across the hazardous waste transportation program. Recommendations included enhancements to shipping procedures, employee guidance materials, record retention practices, training documentation, and internal verification processes. Additional guidance was provided regarding hazardous waste classification documentation, manifest management, and periodic compliance reviews. The goal was to develop a practical system capable of supporting ongoing operations while reducing regulatory risk.
The Results
The client improved visibility into its hazardous waste transportation compliance program and strengthened controls supporting both DOT and EPA requirements. Documentation became more consistent, employee responsibilities became clearer, and management obtained better tools for monitoring compliance performance. Most importantly, the organization reduced the likelihood of costly compliance issues while improving confidence in its hazardous waste transportation activities.
Need help with a similar hazmat compliance issue?
STARS helps companies turn hazardous materials compliance concerns into practical, operationally workable solutions.
Talk With STARS →