The Importance of Auditing Your Treatment, Storage and Disposal Facilities

Railroads operating within the United States generate wastes that often requires proper disposal at various treatment, storage and disposal facilities (TSDF). Waste generators are responsible for the material from “cradle to grave,” which does not necessarily end at the exchange of final disposal documentation from a TSDF. A  relationship remains between the generator and the disposal facility, since the generator retains liability for the waste, regardless of its final destination or disposal location. The TSDF’s are entrusted with handling all aspects of waste disposal, within the applicable federal, state or local rules and regulations, including best management practices. Non-compliant operations by a TSDF facility can lead to fines, site contamination and costs for remedial activities. Therefore, the generator’s waste disposal regulatory exposure is directly connected to how a TSDF operates.

 A recent audit of several TSDF’s varying in both size and type of operations revealed practices and recordkeeping issues that may expose the generator to potential issues. Additional concerns could include unidentified underlying hazardous constituents, inaccurate profiling, identification of the disposal facility operating as a transfer facility versus a TSDF among others.

 The compliance, regulatory and safety records of a TSDF is an indicator of overall facility operations, but should not be solely relied upon to provide assurance. Performing onsite facility audits that review the records as well as a walk through of the TSDF programs, operations and record-keeping can provide a much clearer picture of the generator’s potential liability and whether that information makes the TSDF an acceptable risk.