Original Date: 03/17/1997
Revision Date: 01/18/2007
Best Practice : Hazardous Waste Disposal Audit Procedure
Polaroid recognized that various factors such as new technology, process changes, cost advantage, and vendor replacement can warrant a need for altering a waste stream’s disposal method. To standardize the procedure, Polaroid developed an auditing process for determining the proper means of disposing hazardous waste and selecting vendors and proper treatment options. The auditing process includes a matrix that outlines the appropriate disposal methods for on-site recovery, fuel blend disposal, recycling sales, or disposal via a Treatment, Storage, and Disposal Facility (TSDF).
The approval process begins with a meeting between Corporate Purchasing and Health Safety and Environmental representatives to discuss financial, insurance, health, and safety issues. Next, an audit team consisting of Polaroid purchasing and environmental managers conducts a site visit at the TSDF to review labor relations, permits, site history, and other concerns. The audit team also inspects the site’s operations and processes; reviews community relations; and interviews local regulatory agencies. After completing the site visit, Corporate Purchasing prepares a report which summarizes the audit findings and outlines the business reasons for approving the TSDF. Then an environmental team reviews the report and makes a recommendation for approval or denial to the division that generates the waste. Corporate Purchasing monitors the business and environmental status of approved vendors by conducting follow-up audits within two years. Polaroid’s Code of Conduct governs its procurement operations and states that “excellent health, safety, environmental, social, ethical, and legal standards must be met or exceeded in all sourcing activities by both the company and suppliers.” These principles are also applied to all TSDF vendors and suppliers.
Through its unique auditing process, Polaroid has created a partnership between Corporate HSE, Corporate Purchasing, the divisions that generate the waste, vendors, and suppliers. This partnership ensures the continued protection of the environment and reduces the liability for Polaroid.
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