Hurricane Season Wrap-Up: Reducing Environmental Harm, Regulatory Penalties
Hurricane season, which concludes at the end of November each year, can bring forth devastating harm and damage to retailers across the country.
As if the year 2020 hasn’t already presented us with unimaginable circumstances, the National Oceanic and Atmospheric Administration (NOAA) released an Atlantic hurricane season outlook in early August that called for nearly 25 storms and six hurricanes, which more than doubled the 1981-2010 averages. That outlook has been surpassed – as of late October, Hurricane Zeta became the 27th named storm of the 2020 Atlantic hurricane season, causing severe destruction and fatalities.
With this season being more active than others in the past, it is critical that retailers take the necessary steps to prepare for emergencies and destruction associated with heavy rainfall, flooding and debris as there’s still over a month left of hurricane season. Below, find five elements to keep in mind even as the hurricane season wraps up, and as 2021 emergency response planning comes into play.
Hazardous Waste Disposal Challenges
Retailers can face extreme damage when it comes to extensive flooding, and most debris cannot just be thrown out with the regular trash. When flooding takes place, power outages typically occur, and stores must determine how to dispose of all types of products that may now be considered waste due to lack of refrigeration. You may also need to remove water-damaged products that can no longer be sold such as pesticides, household cleaners or beauty products from stores.
To reduce the risks of injury, environmental harm or regulatory penalties from these products and other debris that you may encounter, a successful disaster response requires extensive knowledge of hazardous materials and waste management, including applicable procedures and regulations at a local and federal level, including those set forth by the U.S. Environmental Protection Agency (EPA) and its Resource Conservation and Recovery Act (RCRA).
The store’s size and the amount of hazardous waste it manages will ultimately determine its status as a generator within RCRA guidelines. The Hazardous Waste Generator Improvements Rule (HWGIR) allows some hazardous waste generators to avoid the burden of a higher generator status. That generator status is an important factor in the case of an episodic event.
Episodic Events and Generator Status
If you have an episodic event that creates high amounts of waste that might qualify you as a large quantity generator (LGQ) versus a small quantity generator (SQG), you can potentially use HWGIR’s relief to not have the hazardous waste material from the event count toward your generator status. Any generator has the option to reach out to the state to see if HWGIR is in effect in their area, which currently consists of 32 states and Puerto Rico.
It’s important to note that just because a natural disaster takes place doesn’t mean that you’ll automatically receive relief or leniency from local regulatory agencies. Document your waste management practices during and immediately after a disaster in addition to any reason that you might not meet compliance. It’s best practice to regulatory agencies ahead of a disaster to ask how your specific retail store can proactively prepare and to determine what actions need to be taken.
Response Plan Communication
Thoroughly communicating with your team is key when it comes to not only determining a response plan, but understanding what actions need to be taken and how each team member will play a part. With COVID-19 precautions in place, many retailers are working with a reduced staff, limiting hours or closing locations altogether, so planning ahead for hurricane season this year unfortunately holds that additional challenge.
With the decrease in workers, you should coordinate ahead of time who will be able to assist in relief efforts, including hazardous waste relief, if and when a hurricane is in effect. Along with this, executives and managers should internally determine emergency response roles. Who will make crucial decisions in the event of a storm? What’s the chain of command and communication plan? Who will be involved in hazardous waste management? Who will assist in waste removal on the ground?
Have this plan in place before it’s needed – the more time you plan with your staff ahead of the disaster, the more you’ll be equipped with knowing how to respond and how to best coordinate with your store’s emergency response partner. Additionally, consider providing webinars and specialized training on how to identify what products are salvageable after a hurricane and what hazardous materials must be disposed of and how to do that properly.
Emergency Response Partner
Prior to any seasonal hurricane plan, it’s recommended to determine a third-party qualified emergency response partner. Although it’s still valuable to train your team on appropriate response measures that can be outlined internally, there are impactful benefits of working with an emergency response partner that will set your team up for success. A third-party partner can help reopen flooded retail locations and provide insight expertise on how to minimize spills and mitigate the damage.
A partner can also guide a retailer on what to document in the case of a hurricane, how to avoid costly fees and what regulatory agencies to connect to in preparation of a hurricane. Documentation of the event, including what items are damaged and what hazardous waste materials are being profiled for disposal, will aid in positioning you to avoid unnecessary fees or penalties.
With every new year comes a new set of challenges for retailers. The frequency of hazardous waste regulation changes, and the frequency of natural disaster episodes, both present obstacles, but there are ways to be positioned for success.
Once this year’s hurricane season has passed, it would be good practice to begin 2021 with clean-out to ensure that your store is meeting all regulation standards. Does your store have a preparedness plan? When was the last time you completed an audit of your hazardous waste storage and disposal practices? Are your choices going to benefit or damage your brand?
Retailers are subject to receiving criticism if they don’t properly rid of damaged products post a natural disaster. Working closely with emergency responders for clean-up effort support will not only get you back on your feet quicker, but it will help mitigate a negative brand perception. The goal for every retailer moving forward should be to reduce the risk of injury, regulatory penalties and environmental harm through the use of a successful and long-lasting disaster response.
Mark Ray is director of national accounts – retail for Clean Earth, which has responded to thousands of environmental emergency calls, providing disaster recovery assistance after hurricanes, tornadoes, floods and other natural disasters. Ray has been supporting national environmental programs across various roles for 10 years and has been part of hurricane response teams on the ground.