|Gossman Consulting, Inc|
Perhaps you have read or seen in the news media that some poultry, beef and pork products in Europe, primarily in Belgium, contained high levels of dioxins and PCBs. Once this was discovered, it touched off a crisis including demonstrations and tumbling prices as consumers stopped buying foods suspected of having been contaminated. This has had a wide impact on all European food exports. South Africa, Russia, China and the United States among others are banning some or all poultry and meat imports from Europe.
How this contamination happened has nothing to do with hazardous waste facilities, incinerators, cement kilns or stack emissions. No matter how anyone wants to spin this, the hazardous waste industry had nothing to do with it. Why then is this a topic of GCI Tech Notes? Simply because of how the contamination occurred. It happened in a manner that we as hazardous waste material managers all fear, a manner in which we hope never happens, but that we keep an eye out for every day.
It may never be known what exactly happened, but it is fairly certain that about eight liters of oil containing dioxins and PCBs was dumped into a public recycling container for used frying oil. This then was blended into an 80 metric ton batch of fats which was sold to a number of poultry and livestock feed production firms. This feed was then distributed to poultry and livestock producers. The batch of fat was produced and distributed in January, but it was not discovered to be contaminated until April when poultry producers seeking the reason for baby chick neural disorders had a state lab test the feed for dioxins. This whole episode is sad and scary. Sad in that it is hard to believe that the person who dumped the eight liters of dioxin and PCB laced oil into the used frying oil recycle container did not know what he was doing. At the best it can only be assumed that he thought it was the used motor oil container, but in either case "proper disposal" this wasn't.
It is scary for another reason, one that those who operate hazardous waste facilities will readily recognize. Was there a waste fats analysis plan? If there was such a plan, it either was inadequate or not rigorously followed. Every hazardous waste facility must have a waste analysis plan. It is required specifically to catch contamination like this.
When was the last time your facility found dioxins or PCBs in a waste sample? I would bet it has been quite a while. It is because of this infrequency that we tend to become complaisant, to believe that "stuff isn't out there any more." But, as the Belgians found out, it is.
GCI urges all hazardous waste facilities, as well as facilities burning waste oil, to take another hard look at the adequacy of their waste analysis plan and check on how rigorously their plan is being followed. That "stuff" is still out there and it could be on the next truck.
GCI assists a number of our clients by reviewing their waste analysis plans and conducting annual laboratory audits. If you would like more information on this service, please contact us.