C2. Hazardous Substances

Code 8.0

Chemicals, waste, and other materials posing a hazard to humans, or the environment shall be identified, labeled, and managed to ensure their safe handling, movement, storage, use, recycling or reuse, and disposal. Hazardous waste data shall be tracked and documented.

Elements to Demonstrate Compliance to RBA Code

1. Policy

Ensure the facility's environmental policy provides that:

• a. Hazardous waste is responsibly disposed of using government-approved and/or licensed vendors.

2. Procedures & Practices

Procedures & Practices are in place such that:

• a. A periodic assessment and corrective action plan process evaluates whether each non-government transport and disposal vendor is complying with contract terms and conditions, with possible areas for improvement recorded.
• b. Only non-government transport and disposal vendors that have approved, current certificates and/or are licensed by the local regulatory authorities are used.

3. Controls & Monitoring

Controls & Monitoring should include:

• a. Hazardous waste inventory records are maintained, tracked, and kept accurate.
• b. Storage points for hazardous waste are inspected and inspection records maintained.

4. Records

Records are maintained including:

• a. Assessments, visit minutes, or audit reports, with possible areas for improvement, are maintained for each non-government transport and disposal vendor.
• b. Hazardous waste inventory records are maintained, tracked and accurate.
• c. Inspection records of hazardous waste and their storage points are maintained, and accurate.
• d. Copies of hazardous waste shipping papers are maintained and accurate.
• e. All non-government transport and disposal vendors have approved, current certificates and/or are licensed by the local regulatory authorities.

5. Serious conditions to ensure do not occur include

• Hazardous waste is disposed of using a non-licensed transport or disposal vendor.

Not Applicable: No hazardous chemical waste generated.

1.2.0 (2023-09-01)

Added

• Hazardous-waste inventory records must now be 'tracked' as well as maintained and accurate: The hazardous-waste inventory record-review requirement changed from 'maintained and accurate' (7.1.2) to 'maintained, tracked and accurate' (8.0.0). The added word 'tracked' is a new previously-unspecified evidence expectation: a facility that maintained accurate-but-not-actively-tracked inventory records could have passed under 7.1.2 and fail under 8.0.0. The change is a single added word on one of five record-review items, capped at the generic Minor/Major rubric (not Priority), so it is ancillary and ruled minor rather than major.

1.1.0 (2022-06-01)

Removed

• Collapsed to responsible hazardous-waste disposal; substance-handling content removed: The two 7.0.0 sub-provisions (substance categorization/handling/storage/controls and waste disposal with reduction program and vendor assessment) collapsed to a single provision covering responsible disposal of hazardous waste using government-approved/licensed vendors, evidenced by five record-review items. The substance-handling content moved to Solid Waste, and the explicit 7.0.0 Major/Minor rating bands were genericized to the scheme-wide finding-severity definition. A strict narrowing/removal of mandatory requirements — no prior pass can become a fail, hence minor.

1.0.0 (2021-01-01)

Changed

• Initial historical baseline — Hazardous Substances (RBA Code of Conduct 7.0, code C3): Earliest imported version (published as C3 in VAP 7.0.0). Covered proper categorization, labeling, handling, storage, transport and disposal of hazardous substances including wastes using government-approved/licensed vendors; controlled access and exposure controls (segregation, secondary containment, ventilation, fire protection, storage cabinets); chemical approval and evaluation of less/non-hazardous alternatives; a hazardous-waste reduction program with annual objectives and a vendor assessment at least every three years; the hierarchy of resource efficiency; and the associated inventory, inspection, manifest and assessment records.