Good Housekeeping & Operating Practices

The objective of good "housekeeping" and operating practices is to minimize material losses and prevent unnecessary hazardous waste generation through routine procedures.

Good housekeeping practices, like in a home, are things which can be done to maintain cleanliness and prevent "messes," spills, or accidents. Good operating practices include other simple steps that minimize waste generation. All industries can benefit from these practices.

Review the following pages to identify good housekeeping and operating practices which have not already been implemented in your facility for:

• purchasing
• inventory control
• receiving
• delivery
• raw materials usage & handling
• proper labeling
• storage
• hazardous materials & wastestream segregation
• empty container management
• preventive maintenance
• training & supervision
• optimizing operations & processes

Good housekeeping and operating procedures often have great waste reduction impact, and involve little capital expenditure or effort to implement. Include them as part of your overall operating plan, and implement them first in order to get the most out of your waste minimization program.

Additionally, savings from these simple measures can often help to offset expenditures for subsequent, more capital-intensive options.

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Purchasing Procedures

Good purchasing procedures will identify and reduce potential waste before it enters your business

• Material Review: Evaluate the materials used by your business, look for less- or non-toxic substitutes, and purchase:
  • The least toxic and least costly-to-handle products that work
  • Higher-purity raw materials
  • Noncorrosive raw materials

• Container Review: Consider your intended use and standard operating practices, and purchase materials in the size and type of container which will minimize material losses and costs:
  • Buy in smaller containers if transfer from large to smaller containers is generally required before use (There will be less potential for spills, material evaporation, contamination from unused material returned to the original container, and expiration of unused materials.)
  • Buy in pre-weighed packages to reduce handling losses (if applicable)
  • Buy materials used often in larger containers (Buying in bulk can reduce the number of containers requiring disposal, especially if refillable containers are used.)
  • Buy containers that are wider than tall (They have less "cling," resulting in greater material use and less container residue.)
  • Buy containers which minimize disposal problems (e.g. filliable pressurized spray cans in place of single use aerosal spray cans)
    Also See "Empty Container Management"

• Chemical Samples: Establish a policy for accepting samples so they do not accumulate and add to waste disposal load:
  • Designate one person responsible for acceptance of chemical samples
  • Test on a bench scale basis to reduce volume needing disposal
  • Require that suppliers accept back the unused samples they provide

• Equipment Evaluation: Prior to purchase, ensure that new equipment:
  • Is that which will generate the least amount of hazardous waste possible
  • Can be easily maintained (Preventive maintenance can save 3-4 times the equipment cost by reducing breakdowns and malfunctions.)
  • Complies with applicable environmental and safety standards (Check with regulating agencies. Use suppliers knowledgeable in these areas.)

• Centralized Purchasing: Channel material purchases through a central person or department to:
  • Eliminate unnecessary purchases
  • Ensure that all waste reduction purchasing policies are followed

• MSDSs: Make certain that distributors supply you with Material Safety Data Sheets for all purchased hazardous materials in order to:
  • Know material hazards, proper safety precautions, and handling and emergency response procedures
  • Comply with worker and community Right-to-Know laws
  • Help you determine the nature of your wastes

• Evaluate Facility Design: Consider waste reduction when planning expansions, and evaluate potential building purchases/leases to determine whether the building design is amenable to waste reduction. Make sure that:
  • Shop equipment can be laid out in an efficient manner
  • Hazardous materials storage areas exist or can be easily installed
  • Space and utilities are available for proper recycling and treatment needs, etc.
  • There are large access doors, wide walkways, and other amenities which can increase ease and safety of operations

Purchasing Property: An Additional Concern

Owning or leasing property could make you liable for cleanup of existing or future contamination. Require the seller to pay for an independent survey to determine and document that the property is free of any hazardous materials contamination or abandoned wastes.

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Inventory Control Procedures

Inventory control procedures are important for reducing management costs and potential hazards associated with excess, off-spec, and expired materials

• Set Inventory Limits: Set according to emergency response capacity. (How large an inventory can your spill/emergency response equipment and personnel handle? The more inventory of hazardous materials, the greater the chance for overcrowding storage areas and resulting safety problems such as spills, exposures and fires.)

• Minimize Inventory: Buy and stock only what you need (Costs associated with hazard risks, hazardous materials fees, and disposal of excess or expired stock may outweigh the costs of waiting for resupply shipments.):
  • Carefully consider large purchases (especially if only to get a discount)
  • Time deliveries to coincide with production needs ("just-in-time" system)

• Track Materials: Effectively track the shelf-life of time-sensitive materials and use the oldest stock first ("first-in, first-out"):
  • Label, date, and inspect new materials as they are received
  • Keep records of dates of receipt and usage to help reduce overstock and material degradation
  • Inventory raw materials at least once per year
  • Consider computerizing your tracking system

• Storage Conditions: Maintain proper temperature, humidity, etc. to reduce material degradation

• Reduce the Number of Similar Products (e.g. If you use several types of solvents, could fewer do the job? Reducing the number of solvents would improve inventory control and enhance recycling opportunities.)

• Look for substitutes with longer shelf lives

• Use waste exchanges for overstock, off-spec, or expired materials

• Work with vendors to accept back excess, off-spec, or expired materials

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Receiving Procedures

Good receiving procedures will prevent acceptance of shipments which are off-spec, incorrect, or improperly packaged, and reduce unecessary waste generation, returns, and spills

• Control all incoming materials by:
  • Receiving them in a specific, designated area
  • Designing the area to prevent and control release of materials

• Train receiving dock employees on proper handling of shipments to prevent property losses, injuries, and costly waste disposal

• Inspect shipments prior to acceptance:
  • Check for opened, damaged, or leaking containers
  • Check expiration dates and ensure proper labeling (see "labeling" pg. 4-4)
  • Test for off-spec materials
  • Obtain MSDS if product is new

• Use quality suppliers (quality and reliability are as important as cost):
  • Supplier should deliver goods intact and according to your specifications
  • Check the track record of your supplier with other companies or references

• Review or create purchase agreements:
  • Specify terms and conditions for receiving material orders
  • Include provisions which allow you to inspect materials prior to acceptance
  • Address responsibility in the event of a release (Specify terms under which each party is responsible for cleanup or other expenses incurred to control an incident.)

• Document agreements to ensure that specified procedures are followed (Remember, suppliers want your business and should be willing to ship on your terms. If not, try to find another supplier or change products.)

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Delivery Procedures

The same measures used to control problems in receiving can be applied to delivery operations to reduce the potential for accidents and associated liabilities

• Request that customers designate a specific area for receiving shipments which is designed to prevent and control accidents and releases

• Request that customers use only workers trained in hazardous materials handling

• Use delivery agreements to limit your responsibility once you have delivered goods to a customer:
  • Require customers to inspect all deliveries
  • Document that the materials have been received in acceptable condition

• Obtain written copies of all delivery agreements to ensure that proper procedures are followed

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Raw Materials Use & Handling

More efficient utilization of raw materials will reduce losses and unecessary waste generation

• Ensure that employees:
  • Use supplies only for their intended purpose
  • Use only the amount necessary

• Keep frequently used hazardous materials near the site of use to minimize spills/accidents

• Provide transfer methods which prevent spills and quality problems:
  • Pipelines for intermediate transfer
  • Gravity spigot or pump to dispense bulk liquid materials
  • A spout and funnel for transferring liquids to different containers
  • Proper connection/disconnection of hoses and lines

• Control access to hazardous raw materials:
  • Designate central personnel to distribute materials
  • Limit access to employees trained in hazardous materials handling and who understand the importance of first-in first-out policy

• Keep records of when and why larger spills occurred in order to identify spill prevention opportunities and document related costs

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Proper Labeling

Proper labeling is extremely important to prevent accidents and extra disposal costs

• Ensure proper labeling of all incoming materials as they are received (Include product name, weight, concentration, lot number, date, hazard class and any other information useful in tracking material location, quality, age or use.)

• Always label hazardous waste at its point of generation where it can still be easily identified (Testing later to determine the contents is expensive.)

• Label all stationary tanks, pipelines, etc. containing hazardous materials or wastes

• Label all portable "squeeze" bottles

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Storage Areas

Well-designed hazardous materials and waste storage areas minimize and contain spills and provide for easy inspection of containers

• Use high quality, resealable containers to prevent spills, evaporative losses, and contamination; and keep the lids/seals closed when not in use

• Arrange raw materials storage with access to front and back of shelving so new materials can be placed behind older stock

• Keep raw material and waste storage area aisles clear of obstructions:
  • Allow elbow room to access all containers easily and minimize spills
  • Space containers to allow inspection for corrosion and leaks
  • Maintain clear, even surfaces on pathways used by workers or equipment

• Keep storage areas clean and well-lit

• Stack containers no higher than recommended by manufacturer, in a way which minimizes the potential for tipping, tearing, puncture, or breakage

• Don't stack equipment against containers

• Make sure containers and shelving or storage areas are earthquake safe

• Insulate electrical circuitry and check frequently for corrosion and potential sparking

• Raise drums off floor to prevent corrosion from concrete "sweating"

• Provide secondary containment and maintain proper distance between different materials

• Install sloped concrete floors and curbs or berms for spill containment

• Cover outdoor storage areas to prevent contamination of storm water

• Secure storage areas to minimize liability and hazards of intrusion or dumping

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Hazardous Materials & Wastestream Segregation

Use of simple segregation practices can prevent accidents or emergencies, reduce waste disposal costs, and enhance recovery/recycling opportunities

• Segregate raw and waste materials

• Segregate incompatible materials/wastes by hazard category to prevent reactions (e.g. strong acids and bases)

• Segregate hazardous from non-hazardous wastes (Never mix non-hazardous waste with hazardous waste - all of it becomes hazardous.)

• Place distinct wastestreams in separate containers and segregate containers holding different wastes

• Segregate empty containers by prior contents

• Set up manned collection centers to prevent unauthorized mixing of wastes

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Empty Container Management

Recycling and reuse are good alternatives to managing empty hazardous materials/waste containers as hazardous waste

• Return empty containers to the supplier: Some empty product containers can be returned to the supplier for refilling. Use a supplier which offers this service. Maintain drums in good condition (with all bungs, rings, and closures in place) for deposits to be refunded.

• *Recondition onsite or contract with drum reconditioner: Drums made of heavy gauge steel can be reconditioned. These cost more, but have a good outlet for minimal or no cost. Maintain drums in good condition (with all bungs, rings, and closures in place) and don't accumulate for long periods to prevent possible deterioration.

• *Reclaim scrap value onsite or contract with scrap dealer

• *Dispose of at a regular (nonhazardous) solid waste facility: Applicable only for containers which hold 5 gallons or less. Consider potential future clean-up liability.

  *To use these options, containers must meet the regulatory definition of "empty" (liquid materials - drip dry; solid materials - scraped clean). "Empty" containers over 5 gallons must be marked with the date emptied and managed by one of these methods within one year. Containers which held acutely or extremely hazardous waste must be completely decontaminated (triple-rinsed) to be considered "empty." Rinsing and treatment other than physical methods (tilt, scrape, chip) requires a treatment permit (from Cal/EPA DTSC). Other procedural and recordkeeping requirements apply. Call the County Hazardous Materials Compliance Division (HMCD) for more information.

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Preventive Maintenance Practices

A strict preventive maintenance program can reduce equipment breakdown, inefficient operation, leakage, and resulting cleanup

• Keep shop clean and orderly

• Curtail water use for spill cleanup and use dry cleanup methods to minimize cleanup wastes:
  • Clean up small spills with rags (do not saturate, keep in covered container) and send to an industrial laundry service (try to find one which recycles its wastewater)
  • Contain and recover fluids for reuse or recycling (squeeze from mop, wring from rags or absorbent mats, use a wet/dry vacuum)
  • Sweep floor using dry absorbent material
  • Reuse absorbents until spent, then dispose of properly

• Periodically test container integrity

• Routinely inspect and address all potential sources of leaks and spills. Check:
  • Process and storage tanks, including all equipment attached to them
  • Pipes, valves, and hoses (Look for leaks at seams, pump seals, and flange gaskets.)
  • Material, waste, and empty container storage areas
• Inspect inventory and other storage areas for improper labeling and aged materials

• Monitor and test all discharges from internal heating and cooling coil quarterly

• Install, and periodically inspect, spill and leak controll equipment:
  • Spill basins on dikes
  • Splash guards and drip boards
  • Overflow control devices, alarms, rupture disks, and relief valves
  • Interlock devices to stop flow to leaking sections
  • Leak detection systems
• Maximize use of welded piping construction, instead of flanged pipe joints

• Use flange guards, double seals, and bellow-sealed valves

• Use pumps with double mechanical seals, or canned (seal-less) pumps

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Training & Supervision

Good employee development and training programs promote waste reduction and the efficient use and handling of hazardous raw materials, and minimize worker exposures and accidents

• Improve operator training

• Improve quality control

• Improve supervisor-employee communication

• Train employees in safe handling of hazardous materials, proper waste management, and emergency/spill response

• Provide additional training in waste reduction practices and increase employee awareness of waste management costs to encourage consistent use of these practices

• Prepare operating manuals or detailed instructions to increase employee safety and efficiency. Include:
  • Detailed descriptions of normal operating practices
  • Listing of process operating conditions and controls
  • Listing of effluent/emission discharge levels
  • Description of overall process and role of each individual position
  • Identification of safety hazards and how to address them
  • Outline of emergency procedures

• Place signs with operating directions on specific equipment

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Optimizing Operations & Processes

Attention to maintenance and operation of process equipment can reduce the frequency of cleanings, and prevent production of off-spec products and excess spent process materials

• Schedule operations to minimize cleanings required ("procedural scheduling"):
  • Schedule jobs in batches and maximize batch size
  • Printing/coating/mixing operations, etc., begin with lighter color and proceed to darker ones, do runs of like colors back-to-back, ("gang-up" jobs)
  • Avoid shifting production schedules for rush orders (May increase waste production by increasing cleaning requirements or causing material scheduled for production to be wasted.)

• Optimize raw material use and minimize residues (which become cleaning wastes):
  • Allow adequate drainage of parts and equipment
  • Use nonstick surfaces and minimize wetted surface area (Cylindrical tanks with height and diameter about equal are most efficient.)
  • Use mechanical or manual wall wipers on tanks
  • Use better process-monitoring systems
  • Routinely calibrate and adjust all automatic process control devices to increase productivity and prevent loss
  • Keep temperatures at optimum levels (note material boiling point on MSDS to minimize evaporative losses)
  • Check mechanical agitators to ensure proper operation and mixing
  • Adjust input material feed flow and purity controls

• Use efficient washing and rinsing methods
  • Eliminate the use of filter aids
  • Use countercurrent and reactive rinsing methods
  • Recycle spent washwater