You work as an EHS manager at a company that makes pallet-racking and materials-handling equipment. It is a medium-sized firm that employs...

You work as an EHS manager at a company that makes pallet-racking and materials-handling equipment. It is a medium-sized firm that employs approximately 140 people on. The racking is painted in a paint department where spent solvents, made up primarily of toluene, xylenes, and solids from the painting process, are causing the company to be on the verge of becoming a large quantity generator.

• Considering the hazardous materials and potential waste streams that could be created, discuss processes that could be changed (management-and/or technology-based controls) in the organization to minimize the waste stream.
• Given that you do not have direct supervisory authority over anyone in the organization, what could you do to gain the cooperation from managers within the organization?
• Identify specific RCRA regulations that apply to this scenario and describe the difference between large and small quantity generators.
• Discuss the potential implications if top management does not take this initiative seriously.