Management Instruction - Hazardous Waste

I. Purpose
This Management Instruction describes Postal Service
policies and identifies guidelines for the safe and
environmentally sound management and disposal of
hazardous wastes. Hazardous waste must be used,
transported, stored, disposed of, and treated in
accordance with federal and state regulations. This
instruction outlines how the hazardous waste
management program will be implemented and
specifies individual responsibilities.
II. Background
A. Laws and Regulations
Improper handling and disposal of hazardous wastes
have damaged water supplies and threatened human
health. Any postal facility that uses substances such
as oil, solvents, paints, inks, pesticides, acids, or other
chemicals is potentially a generator of hazardous
waste and may be subject to federal and state
environmental laws and regulations. The following are
federal laws pertaining to hazardous waste:
a. Resource Conservation and Recovery Act of 1976
(RCRA). Addresses (1) dangers to human health
and the environment posed by improper waste
disposal and (2) conservation of valuable material
and energy resources. RCRA mandates a “cradleto-grave” system that tracks hazardous waste from
its origin through its ultimate disposal. The
Environmental Protection Agency (EPA)
administers RCRA and requires that state
programs be consistent with federal RCRA
regulations. In some states, more stringent
requirements have been added to address special
problems within those states pertaining to the
Distribution
All Headquarters units, Headquarters field units, and field offices
classification, generation, storage, treatment, and
disposal of hazardous waste. Failure to comply
with RCRA regulations can result in costly civil
penalties. Moreover, postal managers and
supervisors who neglect or knowingly violate
certain provisions of the law are subject to
significant individual criminal penalties, including
fines and imprisonment.
b. Pollution Prevention Act of 1990. Establishes a
national policy that pollution should be prevented
or reduced at the source whenever feasible. The
Postal Service is obligated to recycle, minimize
the use of hazardous materials, and purchase
recycled content materials such as refined oil and
other products.
c. Comprehensive Environmental Response,
Compensation, and Liability Act of 1980
(CERCLA). Imposes liability--on any or all
parties responsible for the release of hazardous
substances--for the costs of cleaning up such
substances. Under CERCLA, the Postal Service
remains responsible for the proper management of
waste even after it leaves Postal Service property.
The strict joint and severe liability provisions
established in CERCLA can lead to costly
investigative and cleanup activities at waste
disposal sites.
d. Toxic Substances Control Act of 1976 (TSCA).
Establishes a mechanism for gathering data to
determine the potential health and environmental
risks of chemicals and for using those data to
support restrictions on the manufacture or use of
those chemicals.
e. Clean Air Act Amendments of 1990. Require the
prevention of releases to the atmosphere of
hazardous and toxic agents.
Special Instructions
Organizations fisted under Distribution may order additional
copies from material distribution centers. Use Form 7380, MDC
Supply Requisition, and specify the filing number.
You may redistribute this document by photocopying it, but do
not paraphrase or otherwise revise it.
MI-AS-550-92-8
II-B
B. Pollution Prevention Program
Hazardous waste management is another phase of the
Postal Service pollution prevention program. The first
phase—recycling—is covered in Handbook AS-550,
Recycling Guide. The second phase—waste
reduction—is covered in Handbook AS-552, Waste
Reduction Guide. Specific instructions for managing
hazardous waste will be presented in Handbook
AS–553, Hazardous Waste Management Guide, which
will be published by mid-1992. The guidelines in
Handbook AS-553 will explain what users,
generators, transporters, treaters, storers, and disposers
of hazardous waste must do to comply with EPA,
state, and Postal Service regulations. Forthcoming
phases of the pollution prevention program include
stormwater management, underground storage tank
management, and other programs.
IV. Scope
The policies and guidelines in this instruction apply to
all Postal Service managers, contractors, programs,
projects, products, and services.
V. Definitions
The following terms are central to this instruction:
a. Hazardous Waste. By-products of society that
can pose a hazard or potential hazard to human
health or the environment when improperly
managed. Federal regulations place hazardous
wastes into two categories:
(1) Characteristic Wastes. Wastes that are
ignitable, corrosive, reactive, or toxic.
III. Policy
(2) Listed Wastes. Specific wastes that are
included on any of four lists included in the
RCRA regulations. These lists provide a
means for identifying wastes and assist in
determining the required actions for handling,
storage, and disposal.
A. General
In performing its mission to provide prompt, reliable,
and efficient postal services to all communities, the
Postal Service will conduct its activities in a manner
protecting human health and the environment. The
Postal Service policy is to establish cost-effective
programs to comply with all federal, state, and local
environmental laws and regulations to the maximum
extent possible. In establishing postal regulations and
practices, the Postal Service will, as appropriate,
follow the guidelines for environmental protection that
are set forth in the Administrative Support Manual
550.
b. Toxic Substance. A substance that is harmful to
living organisms—specifically, an asphyxiant,
poison, mutagen (alters DNA), teratogen (causes
birth defects), or carcinogen (causes cancer).
c. Waste. Any material discarded as worthless,
defective, or of no further use that, when disposed
of, may pose a threat to human health or the
environment.
B. Postal Service Priorities
The Postal Service’s highest priority in the area of
waste reduction is to minimize the amounts of
potentially hazardous and toxic substances that it uses.
Postal priorities, listed in order of importance, for
hazardous waste management are:
d. Waste Minimization. The reduction, to the extent
feasible, of hazardous waste that is generated or
subsequently treated, stored, or disposed. It
includes any source reduction or recycling activity
undertaken by a generator that results in (1) the
reduction of total volume or quantity of hazardous
waste; (2) the reduction of toxicity of hazardous
waste; or (3) both, as long as the reduction is
consistent with the goal of minimizing present
and future threats to human health and the
environment.
a. Source reduction.
b. Recycling.
c. Energy conservation and recovery.
e. Waste Reduction. Any change in a process,
operation, or activity that results in the
economically efficient reduction in waste material
per unit of production without reducing the value
output of the process, operation, or activity.
d. Waste treatment.
e. Waste disposal.
C. Compliance
The Postal Service will comply with all applicable
environmental laws and regulations governing its
activities and will not hesitate to exceed legal
requirements when, in its judgment, such action is in
order and is cost-effective.
VI. Objectives
The main objective of the hazardous waste
management program is to investigate opportunities,
identify options, and perform feasibility analyses to
reduce the amounts of potentially hazardous and toxic
materials used by the Postal Service and to ensure
that hazardous wastes are handled in a way that will
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MI-AS-550-92-8
describes methods and procedures for reducing both
nonhazardous and hazardous waste. It presents
management and housekeeping practices that apply to
all postal facilities. The handbook also provides
specific guidance and planning tools to assist
managers in reducing waste in operations at
laboratories, training facilities, printing operations,
and vehicle and equipment maintenance facilities. In
identifying and implementing waste minimization
measures, Postal Service personnel must give first
priority to options that are low-cost over the long
term, are technically easy to implement, and can show
immediate and short-term results. Waste minimization
measures fall into the following categories:
protect human health and the environment and meet
all legal mandates. By implementing a strong
hazardous waste management program, the Postal
Service can achieve additional objectives including:
a. reducing costs, paperwork, liability, and pollution.
b. creating a cleaner, safer, and more efficient work
environment for its employees.
c. developing realistic and safer alternatives to the
use of toxic substances, with the goal of reducing
by one-third by 1994 and one-half by 1995 the
use of 17 hazardous chemicals that have been
identified by EPA’s Industrial Toxics project and
listed in Handbook AS-552, Waste Reduction
Guide.
a. Good Operating Practices.
b. Raw Material Substitution and Product
Reformulation.
VII. Implementation
c. Process Modification.
A. General
The hazardous waste management program has seven
main components: requirements and planning;
training; waste minimization; recordkeeping and
reporting; proper waste handling, storage, and
disposal, emergency response measures; and remedial
actions.
d. Material Reuse, Recycling, and Reclamation.
e. Reduction in Material Volume.
E. Recordkeeping and Reporting
Accurate recordkeeping is essential to a successful
hazardous waste management program. Complete
records are necessary to comply with environmental
regulations and to prepare required reports. It is the
responsibility of postal waste generators to determine
if their waste is hazardous. After a postal manager
determines that the facility generates hazardous waste,
the manager must notify the appropriate state
environmental management agency and must obtain
an EPA identification number used to track hazardous
waste. Hazardous waste containers must be properly
labeled to warn employees of their presence. All
postal generators must use a manifest (cradlegrave) tracking system. They must submit to the
division environmental coordinator, the regional
environmental coordinator, EPA, and the appropriate
state agencies reports on quantities of hazardous waste
generated and disposition of those wastes. All postal
managers whose operations generate hazardous waste
must determine if emissions to air, water, and land
exceed the lowest, minimum thresholds set by local,
state, and federal authorities. If quantities of emissions
exceed the minimum, then all reporting requirements
must be met. In the event of a fire, explosion, or
other release that could threaten human health outside
the facility or when postal management has
knowledge that a spill has reached surface waters,
managers must immediately notify the appropriate
local emergency authorities, division environmental
coordinators, the Field Division General
Manager/Postmaster, regional coordinators, the
appropriate state environmental agency, and the
National Response Center.
B. Requirements and Planning
All postal administrative and operational activities
must, to the maximum extent possible, develop
facility-specific hazardous waste minimization plans.
Hazardous waste requirements and planning teams
must take special care to identify requirements and
hazardous waste streams and to determine the best
ways to minimize those wastes. Hazardous waste
reduction plans include the following elements:
a. Waste-stream assessment
b. Opportunities and priorities.
c. Identification of waste minimization approaches.
d. Feasibility analyses.
e. Facility-specific annual goals at least equal to
national goals.
f.
An annual review of achievements resulting from
program tracking and measurement.
C. Training
Postal managers must ensure that proper on-the-job
training occurs to familiarize them with waste
handling and emergency response procedures and
equipment.
D. Waste Minimization
Reducing the amount of hazardous waste is the most
economical and environmentally sound approach to
meeting legal requirements. Handbook AS-552
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VII-F
minimizing the use of potentially hazardous and
toxic materials.
F. Proper Waste Handling Storage, Shipment, and
Disposal
All facilities must be maintained and operated to
minimize the possibility of leaks, fire, explosion, or
any other unplanned release of hazardous waste or
hazardous waste constituents. Hazardous waste must
never be mixed with nonhazardous waste, and it must
never be disposed of on Postal Service property.
Handbook AS-552 describes acceptable methods for
managing specific types of hazardous wastes on
Postal Service property. Handbook AS-553 details
transportation, storage, and disposal requirements for
hazardous waste.
b. Encourage the purchase of recoverable materials
that are less toxic substitutes for hazardous
materials.
c. Ensure that hazardous wastes are properly stored
and labeled.
d. Conduct, encourage, and promote the coordination
of research investigations, experiments, training,
demonstrations, and studies related to:
(1) Protecting employee health.
(2) Planning and financing waste management
systems, including resource recovery.
G. Emergency Response Measures
All postal facilities where hazardous waste is
generated must have a written contingency plan for
their facility. The plan must be designed to minimize
hazards to human health and the environment. Each
facility that generates hazardous waste must have and
maintain appropriate emergency equipment, such as
fire alarms and spill-control equipment to control
incidental releases; must prominently post the
information that is required in the event of an
emergency; and must ensure that all postal employees
are thoroughly familiar with waste handling and
emergency procedures relative to their responsibilities.
The focus of postal emergency response plans is
notification of appropriate authorities and obtaining
expert help. Trained employees may clean up
incidental spills of hazardous wastes (for example, a
small puddle of liquid near a 55-gallon drum).
(3) Improving methodology of waste disposal
and resource recovery.
(4) Restricting the use of certain categories of
chemical products.
e. Become thoroughly knowledgeable about
regulations pertinent to the operation of a facility
for the treatment, storage, or disposal of
hazardous waste and to the permitting process.
f. Periodically review waste disposal facilities to
ensure that the facilities are complying with
conditions of the permit or regulations and that
manifests are obtained showing proper disposal of
postal wastes.
g. Be knowledgeable of hazardous waste
requirements for transporters and ensure that offsite shipments of hazardous waste are labeled,
marked, and placarded according to U.S.
Department of Transportation and EPA
requirements.
H. Remedial Actions
Postal managers are responsible for ensuring
corrective action. Postal Service policy requires the
use of properly licensed contractors for all hazardous
waste remediation activities.
h. Designate a hazardous waste coordinator for each
facility to assist in the proper management of
hazardous waste and to coordinate remedial
measures in the event of a hazardous waste
emergency.
VIII. Responsibilities
A. General
The Postal Service is legally and socially responsible
for safely managing the materials used in its
operations and the hazardous waste it produces. All
postal managers must determine which, if any, of the
wastes they generate are hazardous, as well as the
quantity of such wastes at their facilities. Managers
involved with hazardous waste must comply with all
policies, regulations, and procedures outlined in this
Management Instruction and adopt strategies
identified in Handbooks AS-550, Recycling Guide,
and AS-552, Waste Reduction Guide, as well as the
forthcoming Handbook AS-553, Hazardous Waste
Management Guide. Specifically, postal managers
must:
B. Headquarters
1. Senior Assistant Postmaster General,
Administrative Services Group. Is the Chief
Environmental Officer for the Postal Service and is
responsible for the overall development of plans,
policies, and procedures to implement this program.
2. All Departments. Must manage their respective
functional areas to ensure compliance with hazardous
waste laws and the intent of this Management
Instruction.
a. Develop and maintain a hazardous waste
reduction program that places highest priority on
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MI-AS-550-92-8
F. Laboratories, Printing Operations, and Training
Facilities
Managers whose operations generate hazardous waste
must ensure compliance with laws and program
requirements. As hazardous waste coordinators they
will be responsible for all recordkeeping and reporting
duties. They will also be responsible for coordinating
responses to hazardous waste emergencies.
3. Environmental Management Division,
Administrative Services Group. Is responsible for
developing integrated environmental policies and
methods for compliance with RCRA, CERCLA,
TSCA, the Pollution Prevention Act of 1990, and
other federal environmental laws and regulations. This
division also will serve as an information center and
assist in developing an education program to provide
information about pollution prevention and the
importance of properly managing—and
minimizing—hazardous wastes.
C. Regions
The regional environmental steering committees must
ensure management participation and compliance at
all levels of the field organization and provide
assistance to field division environmental
coordinators. Regional environmental coordinators are
responsible for program implementation, development,
tracking, monitoring, and reporting; they must assess
postal compliance with environmental laws and
recommend processes or procedural corrections to
deviations from the goal of providing safer, cleaner,
more efficient, and cost-effective solutions to
hazardous waste problems. Regions will provide
comprehensive status reports to Headquarters for the
National Environmental Reporting and Database
System (NERDS).
G. Associate Offices, Stations, and Branches
Postmasters, station managers, and supervisors are
responsible for forming waste reduction teams,
establishing waste reduction programs, and
encouraging employee participation. They are
responsible for developing environmental awareness,
reducing hazardous and nonhazardous materials in
their inventories, and ordering recyclable and recycled
products.
IX. Available Resources and Related
Directives
If questions arise that cannot be answered by this
instruction or the forthcoming handbook, contact the
division environmental coordinators. For issues that
cannot be resolved at the division level, contact the
regional environmental coordinator or the
Environmental Management Division at Headquarters.
If questions arise regarding whether or not a waste is
hazardous, contact state regulatory officials. In
addition, the following documents provide information
relevant to waste reduction:
D. Divisions
Division general managers are responsible for
implementing the hazardous waste management
program through their respective environmental
coordinators who will assist in developing, tracking,
monitoring, and reporting on hazardous waste
minimization projects and programs in their
organizations. The division environmental coordinator
must ensure the implementation of sound
environmental practices outlined in this instruction
and in forthcoming Handbook AS-553. Division
environmental coordinators must develop appropriate
recordkeeping systems for hazardous waste
management and minimization, and they are
responsible for submitting status reports to regional
coordinators.
a. Administrative Support Manual 550.
b. Management Instruction, MI-AS-550-91-10,
Pollution Prevention Program.
c. Handbook AS-550, Recycling Guide.
d. Management Instruction, MI-AS-550-92-2,
Waste Reduction.
e. Handbook AS-552, Waste Reduction Guide.
f . Handbook AS-553, Hazardous Waste
Management Guide (available by mid-1992; an
announcement will appear in the Postal Bulletin).
E. Management Sectional Centers (MSCs) and
Bulk Mail Facilities (BMCs)
MSC Managers/Postmasters, and BMC Managers
where appropriate, must comply with the purpose and
intent of the hazardous waste management program.
These facilities and auxiliary vehicle maintenance
facilities must be assessed for compliance with
program requirements. Managers must act as
hazardous waste coordinators and are responsible for
ensuring compliance at their facilities.
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