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RLA CONSUMBER COMMITTEE WEBINAR. LEADERSHIP CHAIRPERSON Paul Baum CEO. CO-CHAIRPERSON Kathy Murphy Senior Sales Operations Manager. CO-CHAIRPERSON Tony Sciarrotta President. Agenda 1. Introductions 2. Brief overview by Chairperson 3. Introduction of Presenter 4. Presentation

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Presentation by; Jacki Burns Technical Data Manager from Titled:

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Presentation by jacki burns technical data manager from titled





CO-CHAIRPERSONKathy MurphySenior Sales Operations Manager

CO-CHAIRPERSON Tony Sciarrotta



1. Introductions

2. Brief overview by Chairperson

3. Introduction of Presenter

4. Presentation

5. Questions by the audience

  • Presentation by;

  • Jacki Burns

  • Technical Data Manager

  • from

  • Titled:



Presentation by jacki burns technical data manager from titled

Best Practices in Waste ManagementHow Retailers Are Addressing the Issues of Hazardous Waste and Beyond

Jacki Burns

3E Company

October 23, 2013

Hazardous waste exposure

Hazardous Waste Exposure

Waste determination

Waste Determination

  • Notable States :

  • CA, CT, FL, IL, IN, KY, MA, MD, ME, MI, MN, MO, NH, NJ, NY, OR, RI, SC, TX, UT, VT, WA

* 2007 Environmental Resource Center Report: Top 10 Hazardous Waste Violations

  • Most common hazardous waste violation:

    • Failure to determine which wastes are hazardous*

  • 40 CFR Section 262.11 – Hazardous Waste Determination: A person who generates a solid waste, must determine if that waste is hazardous

  • 40CFR Part 271 – State Authorization: State programs have the option to be more stringent than the Federal Standards

Challenges retail product life cycle

Challenges - Retail Product Life Cycle

  • Multitude of Suppliers

  • Obtaining Hazard Data

  • On-Boarding Process

  • Disposition Options

  • Regulatory Scrutiny


  • Multitude of Locations

  • Implementing Policy

  • Consumer Interaction

  • Brand Image

  • Supplier Accountability

  • On-boarding Visibility

  • Speed to Market

Hazardous waste exposure1

Hazardous Waste Exposure

State of preparedness

State of Preparedness

  • Proactive organizations

  • Implemented systems to collect compliance data

  • Ways to identify gaps and/or deficiencies in data quality

  • Methods to evaluate and analyze data for gaps and trends

  • Some integration with other systems

Mitigating risk

Mitigating Risk

Implementing a Comprehensive Program


Documentation and reporting requirements assessment

Disposition Guidance


Program Review



  • Build your chemical and hazardous waste inventory

    • Cleaners, Detergents, Pesticides

    • Cosmetics

    • Pharmaceuticals

    • Batteries, battery operated devices, and bulbs

    • E-waste (TVs, computers, consumer electronics)

    • E-cigarettes, Alcohol over 48 proof

    • Process waste (parts washing, paint tint, photo)



  • Hazard Determination

    • Generator knowledge alone not typically sufficient

    • SDS a recognized viable reference by state agencies

      • Hazardous Constituents and percentages

      • Hazardous characteristics

      • Toxicity

      • Health hazards/warnings

    • Testing



Supplemental supplier data sometimes needed

  • Proprietary, Trade Secret, Missing Data

  • Conflicting data on SDS

  • “Full disclosure” can confuse what’s needed for compliance and delay classification


    Water , Sodium Laureth Sulfate , Sodium Lauryl Sulfate , CocamidopropylBetaine , Cocamide MEA , Hydrolyzed Silk , OleaEuropaea (Olive) Fruit OilOlive , Amodimethicone , Benzyl Alcohol , Polyquaternium 10 , Cetrimonium Chloride , Trideceth 12 , Disodium EDTA , Maleic Acid , Sodium Chloride , Glycine , PPG 9 , Methylchloroisothiazolinone , Methylisothiazolinone , Fragrance , Ext D&C Violet 2 (CI 60730)

Program development

Program Development

What are the labeling requirements for your containers?

What is your generator status?

What documentation is required?

Who will sign if needed?

What are the reporting requirements in each state?

Who will file reports if needed?



  • Container/Drum/Bucket identification and segregation quickly becoming industry standard

  • Distinguish flammable, toxic, corrosive (acid/base), state managed waste

  • Other disposition streams:

    • Vendor buyback/return

    • Secondary Markets/Donation

    • Recycling

Training communication

Training & Communication

  • Coded waste determination available via the scan gun system

    • New industry standard

    • Quick/efficient way to communicate with employees

    • Posters on-site support the program

    • Assigned responsibilities (are items staged? Who can sign?)

    • What if item doesn’t have designation?

Technology trends

Technology Trends

Advancement in technologies driving change

Integrated with ERP systems

Utilization of technologies to move data

Information accessibility & mobile devices

Program scope

Program Scope

Comprehensive Single Program Leveraged to Address:

Damaged Product

Vendor Buybacks

Customer Returns

Expired Product

Regional or nationwide recalls

Unknown/dumped waste

Program review

Program Review

  • Gaps

    • Reconciliation

    • Employee Support

    • Phase 2 Waste – no codes, but not acceptable as trash

  • Opportunities

    • Markdowns of hazmat

    • Expand other disposition options to control costs

    • “Green” product selection

Program review1

Program Review

  • Annual Review

    • Programs costs (disposal costs, training)

    • Total waste generated

    • Hit ratio of classified vs non-classified

    • Support solutions – cost effective? Filling all gaps?

    • Waste Reduction

  • Are all potential waste sources addressed?

  • Is solution meeting all organizational needs?

Presentation by jacki burns technical data manager from titled

3E Company Solutions

Presentation by jacki burns technical data manager from titled

Moving Forward

Contact Information:

Judd W. Dague

District Manager


760-602-8665 office

760-473-0240 cell

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