Definition of "Manage" as used in ISO 14001 related Documents

[drgnrider]

Have a question regarding the word "manage" as used in our ISO-14001 document for "RCRA Non-hazardous industrial Waste". (too new to ISO and not familiar with the definition/intent per federal regs)

Our procedure says:

"RCRA non-hazardous industrial waste streams generated requiring management under this procedure broadly includes, but is not limited to,
? Aqueous liquid wastes or ?wastewaters?, such as spent process equipment solutions, draining of secondary containment, or equipment and floor cleaning wastes"​

Management's definition is basically: 'yeah it goes down the drain, it's managed.' I guess my definition is more "formal", similar to that found at: merriam-webster.com/dictionary/manage

to handle or direct with a degree of skill: as
a) to make and keep compliant
b) to exercise executive, administrative, and supervisory direction of​

While this is not the only one that I have questions about, it is the easiest to explain. So, for the "intent" of "manage" in this instance, as well as for ISO, is their more informal definition correct?

 

[kgott]

Re: Definition of "Manage" as used in ISO 14001 related Documwnts

While I'm not familiar with clause your referring to, I would suggest the word 'manage' means to try and recover, reuse and or recycle or, recover and dispose of as input into another product or process. Any of these options could mean 'manage'.

For sure, if the waste goes down the plug hole then its managed but the question is could it be better managed?

 

[Randy]

Re: Definition of "Manage" as used in ISO 14001 related Documwnts

Let me get this straight.....You posted this?

Our procedure says:
"RCRA non-hazardous industrial waste streams generated requiring management under this procedure broadly includes, but is not limited to,
? Aqueous liquid wastes or ?wastewaters?, such as spent process equipment solutions, draining of secondary containment, or equipment and floor cleaning wastes" and Management's definition is basically: 'yeah it goes down the drain, it's managed.'

Based upon your documented procedure your problem isn't the definition of management, but most likely a serious and willfull violation of the Clean Water Act, because you planned to do it (in the procedure) and unless you can demonstrate otherwise, you acted according to your planning.

When it comes to the EPA and there definition of "management", pouring contaminated waste water down a drain isn't "management"

You might want to see if they can manage finding a good criminal and possibly civil attorney versed in environmental law with a water specialty just in case you need it.

 

[drgnrider]

Apologies, Randy. Before any "questionable" liquids are disposed of, they are tested. The common process waste water has at least been tested initially. After this... might test occasionally.