Making COVID-19 History!
AUGUST 3, 2021
Our priority is to continue to keep our employees, clients and families safe from the COVID-19 virus. We are diligently monitoring and following the guidelines and regulations set forth by the CDC. Please visit the CDC website to view the most up-to-date information.
JULY 7, 2020
If you believe your facility may have been exposed to COVID-19, or if you are interested in preemptively stepping up your cleaning regime to help mitigate disruptions to your business and put your customers and the public at ease, we are standing by and ready to address your specific needs. To ensure the efficacy of our cleaning processes, INGENIUM only uses disinfectants that have been deemed effective by the EPA and CDC recommended cleaning protocols.
APRIL 14, 2020
Myth Busters from the World Health Organization (WHO)
APRIL 13, 2020
Discretionary Enforcement for Hazardous Waste Generators
One of the most important tasks for any of us is protecting the ones we love. This doesn’t just apply to our immediate family, but also to our neighborhood, school and work families. In this regard, some companies may be put in a situation that would require them to discontinue operations in order to comply with shelter in place orders. This blog entry offers some guidance (from a regulatory perspective) on what to consider as you make these decisions.
First, document everything. For example, if you are required to conduct weekly hazardous waste inspections but will have no one on site to conduct them, document the circumstances in advance on your weekly inspection checklist. Or, if you cannot arrange for offsite shipment of hazardous waste because your crew has been ordered to shelter in place, document the rationale on your waste log or shipping papers. If this comes up in a later inspection, the documentation at least provides an explanation of the circumstances.
Second, if you can, arrange for the removal of any hazardous or medical waste that is approaching its regulatory storage/accumulation time limit. This requires a little more foresight as you need to look ahead and anticipate when you might be able to return to your facilities. As a reminder:
Generators are restricted to storing hazardous waste onsite to either 90/180/270 days depending on their generator status and the location of their TSDF.
Generators are restricted to storing medical waste onsite to either 7/30/90 days depending on their generator status and whether they freeze the waste during storage.
Third, you can always apply for a 30-day extension for RCRA waste storage by contacting your local enforcement agency. Guidance for this is found at 40 CFR 262.16(d)[SQGs] and 262.17(b)[LQG] and allows a request for extension if the waste must remain onsite for longer than 90/180/270 days due to unforeseen, temporary, and uncontrollable circumstances. In California and Washington, you can also contact your local enforcement agency if you need to request an extension for Non-RCRA or State only Hazardous Waste.
AND, if you cannot arrange for the removal or an extension…refer to the first item above. Document everything. If you are inspected at a later date and discrepancies are noted, the documentation will at least provide a reason, which should be taken into consideration by the inspector.
The EPA has issued a guidance memo that details discretionary enforcement for issues that arise in the regulated community due to the COVID-19 pandemic. It provides important information for hazardous waste generators:
If a facility is a generator of hazardous waste and, due to disruptions caused by the COVID-19 pandemic, is unable to transfer the waste off-site within the time periods required under RCRA to maintain its generator status, the facility should continue to properly label and store such waste and take the steps identified under Part I.A, above. If these steps are met, as an exercise of enforcement discretion the EPA will treat such entities to be hazardous waste generators and not treatment, storage and disposal facilities. In addition, as an exercise of enforcement discretion, the EPA will treat Very Small Quantity Generators and Small Quantity Generators as retaining that status, even if the amount of hazardous waste stored on site exceeds a regulatory volume threshold due to the generator’s inability to arrange for shipping hazardous waste off of the generator’s site due to the COVID-19 pandemic.
The full memo can be found here: https://www.epa.gov/sites/production/files/2020-03/documents/oecamemooncovid19implications.pdf
At this time, INGENIUM continues to enquire with regulatory agencies regarding any regulatory relief that might be on the horizon for hazardous and medical waste generators. We will update our clients as this information becomes available.
APRIL 2, 2020
COVID-19 – Separating Fact from Fiction
The multitude of news sources and social media hype has inundated us with more information on the COVID-19 pandemic than we can comprehend. As fears increase worldwide, unscientific claims and unreliable advice are spreading fast. The big question is, “How do you separate fact from fiction?
Because of the nature of our business and the importance of being aware of the latest coronavirus updates, we have curated information about COVID-19 from a variety of reliable sources such as the Center for Disease Control and the World Health Organization, and created a course module that will offer an in-depth look at what a coronavirus is and what makes COVID-19 unique.
The course provides valuable information including how the disease spreads, what symptoms to look for, prevention strategies, what to do if you or someone you know is infected, and a list of frequently asked questions that are on everyone’s mind. It’s important to note that this course is dynamic and will be updated as new information becomes available.
We hope you find this information valuable and encourage you share with family and friends. Don’t forget to check back for important updates.
At INGENIUM, our number one goal is safety, and we would like to thank you for partnering with us to control the spread of COVID-19.
MARCH 31, 2020
Notification to INGENIUM of Exposure at your FacilitySafety is our number one priority, so we want to be diligent in taking all precautions necessary to protect our employees, our clients, our families and our communities.
As we navigate through the uncertainty of the COVID-19 pandemic, we are asking that you inform us promptly if you have had a positive diagnosis or an active case of the virus in your facilities so we can inform INGENIUM employees who may have performed services at your location.
Below is an excerpt from the CDC guidelines on notification recommendations should a business have an active case, along with a link to the complete CDC guidelines. Again, we ask that you please include INGENIUM in your notification process.
Separate sick employees:
MARCH 27, 2020
INGENIUM Provides Essential Clean-Up Services for COVID-19
As COVID-19 continues to spread through the country and our local communities, we are all likely to be affected and feel the impacts in both our business and personal lives. At INGENIUM, safety is our number one priority and our commitment is to ensure and adhere to the safety goals of our company, our employees and our clients to protect You, Me and the Community.
As we are considered an essential business according to state and federal guidelines, INGENIUM is available, prepared and ready to respond to incidences that may threaten the health and safety of others and the further spread of this virus. The Coronavirus (COVID-19) pandemic has driven the need for many organizations to implement business continuity efforts related to cleaning and disinfecting of areas impacted or potentially exposed to COVID-19. To ensure the efficacy of our cleaning processes, INGENIUM only uses disinfectants that have been deemed effective by the EPA and CDC recommended cleaning protocols.
If you believe that your facility may have been exposed to COVID-19, or if you are interested in preemptively stepping up your cleaning regime to help mitigate disruptions to your business and put your customers and the public at ease, we are standing by and ready to address your specific needs.
We look forward to partnering with you to create an effective and efficient response plan to keep your employees, your families and your communities safe.
MARCH 17, 2020 – For California Customers
INGENIUM Exempt from Shelter in Place Orders – Essential Business
I am aware of the “shelter in place” orders taking effect across the State. INGENIUM’s position is as follows:
INGENIUM will continue to service our clients as allowed by the pertinent regulatory authorities. I am taking nothing for granted in these changing times, and I think communication is key to making this time as least disruptive as we may. INGENIUM is one of your partners in this, and I am committed to doing everything we can to support you.
MARCH 16, 2020
INGENIUM Activates “Remote Workplace Plan”
On Friday, in response to the spread of COVID-19, I made the decision to activate INGENIUM’s Remote Workplace Plan. We live by the motto of “Protecting You, Me and the Community” and, therefore, INGENIUM must stand up and do its part to help prevent the spread of this virus. If the spread of this disease is not slowed, COVID-19 may cripple the healthcare infrastructure in the US.
You have likely heard about the concept of “social distancing,” which is one of the last tools at our disposal to help slow down the infection rate. Working from home is one way to help with social distancing, which is so critical to slow the spread of this disease.
Over this week, staff who can effectively perform their duties from home are being transitioned into a home-work environment. Staff who are service-critical and who can’t perform their duties from home will be practicing other social distancing protocols, such as staggered scheduling to minimize the number of staff in one place at the same time. We are taking these steps to help protect the larger community in which we all exist.
I expect this transitioning time to be disruptive to our operations, and I would ask for your patience as we get staff stabilized in new work environments. You may experience a delay in returned emails and phone calls, and you may experience short delays in service should any of our field staff contract the virus. I appreciate your understanding in this.
Further, our EH&S staff has been closely monitoring governmental policy developments and guidelines. They advise all clients to do a thorough documentation of any COVID-19 related lapses in compliance. This may help in future audits or inspections to help put the non-compliance issue in context.