For companies with oil-intensive operations such as manufacturing, assembly, repair, and maintenance activities, finding effective management solutions for petroleum-contaminated byproducts (e.g., rags, wipers, towels, and absorbent matting) has been a balancing act between ensuring compliance with jurisdictional waste regulations and operational cost control, not to mention the added concern of finding a solution that aligns with your company’s sustainability goals. To help clarify the options available, let’s run through the most favored management methods over time selected by companies that face this dilemma, as well as highlight an opportunity that offers the best balance of compliance, sustainability, and cost efficiency.
Tossing your oil-contaminated waste absorbents into the trash seems like a management ‘quick win’; throw it in the trash, and it is gone ‘forever’. It’s been the standard management method for companies and communities for ages. However, over time, this method has become more expensive and more restrictive due to environmental regulations. Should you landfill waste absorbents, your responsibility as a generator is to ensure that the materials are adequately characterized in order to meet regulatory guidelines imposed by USEPA, State environmental agencies, and local ordinances. As the generator and disposer, your liability for the waste absorbents will never be relieved; you are responsible for the environmentally safe generation, transport, and disposal of these wastes. Further, you will be a potentially responsible party in perpetuity for human health and/or environmental issues associated with any release to the environment from that landfill.
While disposing of your waste-absorbent materials appears as simple and cost-effective on the surface, added costs for appropriate waste characterization, profiling, landfill rates, and tipping fees drive up the overall expense. Further, your integrator and disposal site may drive additional costs through the application of additional management and formatting requirements in order to comply with their regulatory permits and contractual obligations.
An often overlooked expense component is the linear (as opposed to circular) nature of landfilling waste; as little to none of the waste components are reused, reclaimed or recycled, more natural resources (i.e., manufacturing feedstock and intermediates, energy, and labor for processing, packaging) are required to be consumed in order to replenish company absorbent inventory. This non-circularity element can significantly undermine your company’s sustainability initiatives (e.g., zero landfill) or ‘green procurement’ policies.
Overall, landfilling waste absorbents may appear to be the ‘simple’ alternative for your company, but its share of pitfalls from compliance, sustainability, and cost standpoints, makes exploring other waste absorbent management options a ‘must-do’.
Waste incineration, including incineration for energy recovery, gained popularity in the United States in the 1970s as communities became more aware of the potential environmental and health hazards associated with landfill disposal. Originally considered an improved, more practical method of waste management than landfilling, it has actually posed a more diverse set of environmental consequences to companies and the communities in which they are located.
Collection and management of your waste absorbents on the front end are nearly identical to the methods and pitfalls associated with landfilling; the same generator responsibilities, characterization, profiling, and additional fees and surcharges are present when dealing with incineration as a disposal method. Your long-term liabilities for environmental issues are also still present, as the waste ash from incineration is disposed of in landfills.
From an expense perspective, waste incineration requires extensive and complex machinery and equipment, as well as complicated environmental permitting and monitoring obligations, the costs of which are passed on to the customers. Incineration of your waste absorbents comes at a significant cost premium relative to landfills, not to mention surcharges and markups applied by waste integrators. Despite all of the added expense, there is really no reduction in liability for the customer. In addition, even incinerators in full compliance with environmental permits and industry standards emit massive amounts of diverse pollutants into the atmosphere and water every year, exposing sensitive populations nearby to potentially hazardous environments.
Similar to landfilling, incineration also does not perform well from a sustainability standpoint, as the waste materials are destroyed, thereby requiring more natural resources to replenish the company’s absorbent inventory. Again, this linear economy model (i.e., manufacture…purchase…use…destroy) undercuts the cost efficiency and sustainability standard your company is looking to achieve.