Wastewater – Level 1 – Is hazardous sludge (chemical / industrial) disposed of properly? Higg Index By compliancemenu

How is your sludge disposed of?
  • Hazardous Waste Treatment
  • Incinerated controlled conditions
  • Landfilled
  • Open burning
  • Fuel Blended
  • Composted
  • Fertilizer (applied to land)
Upload: a) Sludge analysis or test results from last 12 months (if non-hazardous is selected); b) permits or manifests for proper disposal or land application.
If you have hazardous sludge it must be disposed of through a licensed hazardous waste contractor or through incineration under properly controlled conditions.

What is the intent of the question?
You should know if there are any chemical or industrial hazards present in your operations, and, if there are, you need to make sure you do not dispose of these hazards improperly.
Hazardous sludge needs to be disposed of properly to avoid contaminating the environment. If you put hazardous sludge onto land or burn it openly, you can release serious hazards into the environment.

Technical Guidance:
Sludge should be properly disposed through authorized agent or facility should have licensed by local pollution board to decompose it in premises. Chemicals should be handled and disposed in accordance with MSDS section 13. In cases where the local government has classified the sludge under non-hazardous waste then the test report of sludge analysis may not be necessary. However, landfilling and open burning activity in-house may not be appropriate unless it is clearly identified through sludge analysis that the sludge is non-hazardous in nature.

How this will be verified:
 Yes

Documentation required
  • An inventory of the amounts and types (non-hazardous and hazardous) sludge generated
  • Lab analyses showing the non-hazardous and hazardous (if applicable) components for the various types of sludge
  • Documentation showing methods for disposing each type of sludge
  • For off-site disposal, invoices or delivery records confirming that the types of disposal selected here reflect what’s being used in practice
  • If disposal is done via landfilling, open burning, compost, fuel blended, or as fertilizer applied to land, the sludge must be analyzed and documented as non-hazardous and suitable for the particular disposal method.
  • Permits, if applicable for a particular disposal method
  • Interview discussions
  • Is there an in-depth and up-to-date knowledge of the sludge components? How is sludge regularly analyzed to ensure it is properly disposed of?
  • Is management and responsible employees aware of proper disposal methods for each type of sludge
  • Inspection – things to physically look for
  • Site or area and process for disposing of sludge if it is one on-site
  • Please take photographs

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