The following article was published in the Hazardous Material Management Magazine, Feb/Mar 2000 edition.

As most Canadian waste generators have realized, ownership (and potential liability) for waste can linger long after the waste has left the plant. Many waste generators have responded by implementing liability risk assessments for waste receivers. Clearly, a tremendous amount of effort is required to assemble the information necessary to complete a full liability risk assessment. In addition to permit status and technical capabilities, key issues such as environmental setting, financial wherewithal, insurance, operator competency, and closure costs are deemed vital in these risk assessments. Now picture the dilemma of the waste facility operator. In order to secure the business of each new waste generator, a new audit would have to be completed. The auditing process frequently involved several days on site by the generator and interviews with key technical staff. Regardless of perspective, waste facility audits incurred significant costs and disrupted operations.

In 1996, the Western Canadian Auditing Roundtable (WCAR), a committee comprised of prominent western companies with an interest in Health, Safety and Environmental auditing embarked on a cooperative solution. WCAR's primary objective was to develop a 'best practices protocol' that would universally address the risk assessment concerns of any waste generator. "At a preliminary meeting with several key waste companies, the waste facility operators implored us (the waste
generators) to adopt a single standard for the waste facility audit. The concept sounded simple enough," commented Bill Peel, Environmental Auditing Manager for Atco Electric. "Each of the WCAR members brought their waste facility audit protocols and threw them on the table." The protocols ranged in size from 5 to 65 pages. With help from environmental consultant, AGRA Earth & Environmental Ltd, WCAR amalgamated the various corporate assessment protocols with those from other industrial associations to produce the new, comprehensive protocol.

"We recognized immediately that we couldn't develop an audit protocol that would address every company's needs directly," observed Wit Siemieniuk, Project Manager for AGRA. "Instead, we settled on a questionnaire that, when filled out correctly, would provide all of the information to complete anyone's corporate risk assessment." The development process included pilots at three typical waste facilities. The result is a questionnaire, that when completed by the waste receiver, provides the generator with the necessary information to evaluate the environmental, operational and financial risk of that facility. The integrity of the document's contents is maintained by having the waste facility hire a third party verifier to confirm the accuracy of the information. Verifiers must employ environmental auditing principles and comply with the Canadian Environmental Auditing Association Code of Ethics. They also must belong to a professional organization that has a discipline procedure, such as Certified Environmental Auditors, P. Eng. or P. Biologist. The verified WFER is "owned" by the waste facility.

Over 40 companies have endorsed WFER as their primary risk assessment data source. Many companies require that their waste contractors complete WFERs as a condition of continuing business relations. "There is little doubt that contracting only with companies that have completed WFERs has heightened the awareness of this program," notes Gary Burns, Environmental Manager for Syncrude and Chair of WCAR, " but it is important to note that having a verified WFER is not a WCAR-certification nor a guarantee of business from the endorsing companies. Each generator has his own risk tolerance, so must complete his own risk assessment."

Although the vast majority of WFER activity has been in Western Canada, there has been recent interest emanating from Ontario. Adds Gary Burns: "There's increasing interest from Eastern Canada as affiliates to WCAR companies begin to adopt the WFER process. We're also receiving support from large manufacturers and industrial associations such as the Canadian Petroleum Products Institute and the Canadian Association of Petroleum Producers." Approximately 45 WFERs have been completed to date. "With this wide usage, the WFER has become the industry best practice standard - and thus, defines what due diligence looks like for waste generators."

Waste generators aren't alone in recognizing the benefits from the WFER program. Don White, Operations Manager for the Safety-Kleen (Ryley) Ltd, stated that "WFER achieved its main objective of reducing the time spent in long waste facility audits. We used to entertain 4 to 10 large audits that would consume 5 to 10 weeks of effort annually. With WFER, we've reduced that effort to about a week." Don notes that WFER also provides a significant benefit to the waste generator. "Many of the smaller waste generators simply don't have the resources or skills to under-take a detailed audit." Adrienne Turner, Marketing Manager for Bovar Waste Management Inc., noted that prior to developing their WFER, the Swan Hills Treatment Facility received at least four major audits a month. "Our production was severely hampered because key technical staff were being pulled away from their regular duties to participate in these audits. WFER has reduced the assessment process requirements from three days to one day per week. We've also seen benefits in using our WFER for public relations and as an internal information resource."

With the WFER process receiving such widespread generator endorsement and completion by waste receivers, it truly has become a win-win solution.

The WFER protocol/questionnaire and Guidance Manual may be downloaded for free from the WCAR web site at www.wcar.org. The site also contains a description of the process and a listing of the waste contractors that have completed WFERs.

Morley Kostecky is an industrial waste management specialist at Kostecky Environmental Ltd. In addition to providing input to the revision of the WFER form, he was the lead verifier in seven WFER projects including the Bovar Swan Hills Treatment Centre.

Richard Hart is an HSE Coordinator with Shell Canada Limited, Chair of the WCAR WFER Committee and a Director of the Canadian Environmental Auditing Association.