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APPENDIX 2 <br /> HAZARDOUS WASTE MANAGEMENT PLAN <br /> Identification <br /> The first step in disposal of a hazardous waste is to determine whether or not it is actually a <br /> hazardous waste. The Environmental Protection Agency (EPA) has instituted waste lists and <br /> characteristics that can assist in the determination of hazardous waste. UFP will use the <br /> following criteria to determine whether or not a waste is to be considered hazardous: <br /> • The material is listed as a hazardous waste in 40CFR Part 261 subpart D. <br /> • It has hazardous waste characteristics of ignitability, corrosivity, reactivity, or <br /> toxicity. <br /> • It is a mixture of a hazardous waste and a non-hazardous material. <br /> • Solid waste, scrap or debris removed from the drip pad. <br /> • It is determined by to exhibit toxic characteristics as determined by a TCLP. <br /> Any questions concerning hazardous waste determination should be directed to WPD in Grand <br /> Rapids. <br /> Waste chemicals should never be placed in the trash or dumped down a drain unless it is known <br /> that it is not a hazardous waste and it is acceptable for disposal through such means. Special care <br /> should be taken when disposing of any hazardous waste not to mix it with any material that may <br /> create an adverse reaction. After you have decided that the material is a hazardous waste, it <br /> should be managed as such. <br /> Management of Hazardous Waste <br /> Please consult Wood Preserving Manual policy #2061 for specific details on management of <br /> hazardous waste. <br /> Waste Reduction (also WPM 2009) <br /> By Law, UFP is required to make efforts to reduce the amount of hazardous waste we generate. <br /> Therefore, plant staff should take the following measures: <br /> • Buy only those amounts of hazardous materials that can be used before the expiration <br /> date of the material. <br /> • Use up the material by using it for its intended purpose <br /> • Determine if another plant operation has a need for, and can use the product <br /> Training <br /> Hazardous Materials training is provided annually by WPD for those who generate hazardous <br /> waste. If staff feel unprepared to handle hazardous materials, their concerns should be brought <br /> to management immediately. Training is documented in the red files. <br /> 11 <br />