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OBJECTIVE
The purpose of this standard is to define the minimum requirements for the evaluation of Waste Management
Contractors to assure regulatory compliance, and to minimize risks to the environment and potential liabilities
associated with the management of hazardous, toxic or “Special Focus” waste from Covidien facilities. All
waste generating Covidien locations must establish Waste Management Contractor evaluation programs. The
requirements set on this standard are common to all Covidien facilities to assure proper environmental
compliance.
2.0 SCOPE
This standard applies to all waste generating Covidien sites including, all administrative offices,
manufacturing plants, laboratories, nuclear pharmacies, research and development (R&D) facilities, and
distribution centers/facilities. It applies to the management of all wastes from these sites, which are classified
as hazardous, toxic, or “Special Focus” waste. It may apply to some wastes that are not regulated as
hazardous or toxic, but which, in the opinion of Corporate or Business Unit EHS leaders, may represent a
concern or a hazard to the environment
Compliance with this standard is mandatory.
Where national, provincial/state, or local legislation or regulations exceed or differ from the guidelines of
this standard, those legislations and regulations take precedence. In the case where the legislation and
regulations have requirements that are similar to those on this standard, the most stringent requirements
must be followed, if and only if regulatory compliance is not compromised.
3.0 ATTACHMENTS:
Attachment A – Waste Management Contractor Nomination Form and Process
4.0 DEFINITIONS:
Approved Waste Management Contractor – An entity “approved” by the Business Unite EHS Director for
the handling of wastes covered under this standard, including waste packaging, transportation, treatment,
storage, recovery and/or disposal. For the purposes of this standard, the term “approved” is limited to
transporters and other contractors that have been evaluated following the requirements established in this
Standard and are under waste management services contract with Covidien.
Hazardous Waste - Waste which meets the definitions of “hazardous waste” contained in the national/federal,
provincial/state and local regulations.
Special Focus Waste – Waste for which its handling, transportation, recycle, reuse or disposal may be
regulated by national/federal, provincial/state or local regulations. This specifically includes waste that
contains pharmaceutical chemicals, chemical raw materials or waste products, electronic waste, radiological
waste, empty waste or chemicals containers, bio-hazardous waste, remediation or cleanup waste including but
not limited to contaminated soils and debris, universal waste, and other recyclable waste that could be
classified as hazardous or toxic upon disposal. This term excludes general solid waste, rubbish or garbage,
non-regulated building materials or debris, non-hazardous recyclable material and wastewater.
ENVIRONMENTAL HEALTH & SAFETY (EHS) STANDARD
WASTE MANAGEMENT CONTRACTOR EVALUATION
STD.8.101
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Toxic Waste - Waste which meets the definition of “toxic or dangerous waste” contained in the
national/federal, provincial/state and local regulations.
Waste - It is any residual from an activity, product or service that can no longer be used for its intended
purpose. It is to be discarded, or it is incidentally generated during a manufacturing operation. For the
purposes of this standard, wastes are transported off-site for recycling, reuse, treatment and/or disposal.
Waste Chain - Entities involved in the waste management process from its generation through its final
disposition, otherwise known as “cradle to grave”.
Waste Management Services Contract (Contract) – Documented and signed agreement between a Covidien
facility and a Waste Management Contractor where general terms and conditions, services, responsibilities,
liabilities and prices are defined. A Purchase Order is considered a complement to a contract but not a
contract.
5.0 PROGRAM GUIDELINES
5.1 Responsibilities
5.1.1 Site EHS Manager/Coordinator
Site EHS Manager/Coordinator shall:
• Ensure that site management is aware of the regulatory requirements and obligations of waste
management.
• Facilitate the implementation and administration of this standard at the site.
• Nominate proposed Waste Management Contractors to the Business Unit EHS Director to be
reviewed for approval.
• Collect the necessary documentation to cover the requirements of Section 5.3 of this standard for
the evaluation of a nominated contractor.
• Ensure all applicable waste management regulations are being met and all Waste Management
Contractors utilized by the facility are approved vendors.
5.1.2 Site Management
Site Manager/Director, and the management staff, shall:
• Ensure the Standard is implemented at the facility and applicable waste management regulations are
met.
• Ensure programs are implemented and maintained to meet the requirements of this standard.
• Ensure proposed Waste Management Contractors are nominated to the Business Unit EHS
Director for review and approval.
5.1.3 Business Unit EHS Director
The Business Unit EHS Director shall:
• Ensure this standard is distributed and implemented at all applicable Covidien sites.
• Support sites in the implementation of this standard by providing guidance and assistance in the
development of applicable programs. .
ENVIRONMENTAL HEALTH & SAFETY (EHS) STANDARD
WASTE MANAGEMENT CONTRACTOR EVALUATION
STD.8.101
PAGE 3 OF 12
• Ensure sites are meeting the requirements set in this standard. .
• Ensure sites are meeting the necessary requirements for the selection and use of Waste Management
Contractors. .
• Obtain facilities’ nominations for proposed Waste Management Contractors.
• Develop, in coordination with the Vice-President of EHS, a list of approved Waste Management
Contractors who are properly licensed or permitted, are in compliance with applicable laws and
regulations, and manage waste to minimize harm to the environment. Perform reviews or audits
prior to recommending approval of a Waste Management Contractor.
• Conduct subsequent periodic reviews or audits to ensure compliance is maintained. Such reviews, or
audits, are to be conducted at intervals not to exceed three years.
• Forward the results of the above reviews, or audits, to the Vice-President of Legal – Chief EHS
Counsel and obtain his/her concurrence that any approved Waste Management Contractor used does
not represent an unreasonable risk to Covidien.
• Request assistance from the Site EHS Manager/Coordinator if the necessary resources are not
available to conduct facility reviews.
• Ensure Waste Management Contractors used as part of a Business Unit Master Services Agreement
are approved to provide waste services to Covidien.
5.1.4 Vice-President of EHS
The Vice President of EHS shall:
• Ensure this standard is distributed and implemented at all Covidien sites, as applicable.
• Support the Business Units in the implementation of this standard by providing guidance and
assistance in the development of applicable programs, and meeting applicable regulations.
• Ensure sites are meeting the requirements set in this standard.
• Ensure sites are meeting the necessary requirements for the selection and use of waste handlers.
• Provide assistance to the Business Units in the audit and approval of Waste Management Contractors
when requested.
• Maintain, in coordination with the Vice-President of Legal – Chief EHS Counsel, the current list of
Approved Waste Management Contractors.
• Advice interested Covidien sites of association plans when the use of association audits represents an
advantage to Covidien.
• Ensure Waste Management Contractors used as part of a Corporate Master Services Agreement are
approved to provide waste services to Covidien.
5.1.5 Vice-President of Legal – Chief EHS Counsel
The Vice-President of Legal – Chief EHS Counsel shall:
• Ensure sites are meeting the requirements of this standard.
• Maintain, in coordination with the Vice-President of EHS, membership in associations which
conduct audits of Waste Management Contractors.
• Support the Business Units Directors and the Vice-President of EHS in the approval process of
Waste Management Contractors.
• Negotiate, finalize and execute waste management service contracts.
5.2 Commitment to Evaluate
As a waste generator, Covidien is committed to the responsible care of waste that has been within our control.
This includes preventing the transportation, recovery, disposal, treatment, storage or disposal of waste
• With proper regulatory authorization (such as a permit or license), where applicable, or;
ENVIRONMENTAL HEALTH & SAFETY (EHS) STANDARD
WASTE MANAGEMENT CONTRACTOR EVALUATION
STD.8.101
PAGE 4 OF 12
• In a manner that prevents pollution or harm to health.
Each Covidien facility is responsible to ensure that wastes covered under this standard are handled by
Covidien approved Waste Management Contractors only. In regions where corporate master service
agreements or contracts exist with pre-selected Waste Management Contractors, facilities shall only use waste
handling companies within the scope of those agreements. Where corporate master service agreements or
contracts do not exist, or, where necessary services are not covered, sites are responsible of identifying and
nominating potential Waste Management Contractors to their Business Unit EHS Director for their assessment
and approval. The nomination shall include the necessary documentation to support the requirements of
Section 5.3 and justification for use. The facility shall present in their nomination a written justification for
selecting the corresponding W
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