Off-spec Process Flow

What is an Off-spec? An off-spec refers to any drum, which upon sampling and analyzing, does not exhibit the characteristics representative of the waste class code assigned to the profile. When a waste is off-spec, the receiving facility will designate a new waste class code that more accurately represents the waste’s characteristics. Compliance specific off-specs may be identified prior to sampling through the receiving program and paperwork review process.

Purpose Scope Provide mechanism for service personnel to manage off-spec wastes with our customers. Provide service personnel with the resources needed to understand the reasons for the off-spec. Provide guidance for determining the appropriate off-spec rate. All personnel who manage customer accounts and service to those accounts to receive a comprehensive off-spec report daily. Communication to customer is made with confirmation of appropriate charges to be applied. Billing instructions added to the orders.

Nightly Off-spec Report The report will be pushed out nightly and will capture information based on the following logic. 1) Process code applied by the facility differs from profile waste class code(Pre-code). Time period: These off-specs will remain on the report for 48 hrs from the date of entry, excluding weekends. 2) Process status applied by the facility is OFFC, OFF$, OFFC$, RTG, RTAF, and HOLD. Time period: These will remain on the report for 15 days. OFFC: Compliance problem requiring resolution. Facility compliance managers responsible to drive timely resolution of all compliance related off-specs. OFF$: Off-specs where the change in handling cost is significant and may require special attention from the Account Owner. OFFC$: Both Compliance and significant cost implications. RTG: Return to generator. Facility compliance managers responsible to drive timely movement of the waste back to the customer. RTAF: Reject to Alternate Facility. Facility team to determine appropriate alternate facility. Customer Service responsible to coordinate transportation of the waste to the alternate receiving location. HOLD: Problem drums needing further QC or issue resolution. RSMP: Drums to be re-sampled. NOTE: Customer Service and Sales organization responsible for all communication with the customer.

The Report Invoice Status Sorted by Branch code then by Job Owner. Off-specs grouped by Process status. Includes the following key pieces of data: Receiving Plant Waste class codes: Pre, Test, and Process. Receiving comments outlining the factors causing the off-spec. Invoice Status

Establishing an Off-spec Price Once the off-spec waste class code is determined use the following hierarchy to apply a price to the waste. Contract Waste Class Code Price: Apply appropriate contract price if one exists for the waste class code in question. Contract Profile Price: Apply price based on profile specific pricing for streams of the same waste class code. If multiple profiles with same waste class code but pricing varies, establish price using #3 Customer Ranking. Customer Ranking: Apply SRP from pricing tables based on customer ranking. Premium Pricing: Apply premium pricing whenever possible for off-specs. We do incur administrative cost in addition to an increase in handling and disposal costs. Note: The billing department will be using the same process to establish a rate. The billing team is tasked with processing invoices as quickly as possible therefore it is imperative that Off-specs be addressed immediately. Invoicing will not be held up pending information from the field.

Responsibilities Customer Service Personnel: Review report daily. Identify off-specs requiring attention: Push for supplemental invoices for invoiced jobs when appropriate. Communicate with Job Owner and/or Account Manager as needed. Contact customer as needed to resolve compliance and pricing issues. Provide documentation to compliance personnel with OFFC issue resolution information. Record pricing requirements in Billing instructions at the order level as needed. Facility Managers Validate final coding being applied properly to all drums. Ensure that proper descriptive comments entered for all off-specs. Compliance Managers Drive resolution of Compliance related off specs. Update drum data base as resolved. Upon resolution, update process status codes to YES. Note: If Lab Comments field does not provide sufficient information explaining the off spec, utilize the resource information on the following slides to determine cause of off spec.

Supplemental Invoice Guidelines Minimum $100 potential revenue to be captured through supplemental invoicing. Email details to Billing Manager distribution list. Sales order number Manifest # and line item Profile # and off spec drum quantity Off-spec reason(s) and charges to be billed Include any applicable surcharges that may be related to the off-spec waste class code. Billing Supervisor to review and delegate to appropriate biller for processing. Detail item to be used: SUPINV “Supplemental Charges, Non-conforming Waste” Comment line added to include summary information listed above. Note: there is limited character space available. One SUPINV line to be added per Manifest line. Invoice Preview to be posted for field review. Supplemental Off Spec invoices will NOT go back to the Audit Team.

Issue/Dispute Resolution Customer disputes our QC results: Immediately notify appropriate plant GM or Operations Manager to resample individual drums. The process status for the drums will be changed to RSMP (resample). The field person must also identify the appropriate coarse of action to be taken when resample analysis is complete. Process Status “Yes” upon completion of resample analysis. Samples requested to be sent to third party for certified analytical at the customers expense if our plant analytical is confirmed. Waste returned to generator or rejected to alternate third party facility at the customers expense. Customer disputes our price: Immediately notify billing of the dispute. Add notes through unbilled report as needed. Contact AM or local GM(for unassigned accounts) Develop appropriate response for customer. Clearly identify who will communicate with the customer to close out the issue. Options: Bill at off-spec rate based on pricing guidelines. Appropriate alternate rate negotiated and billed. Bill at original price one time only. Make sure customer is aware of appropriate off spec charges moving forward. Waste returned to generator or rejected to alternate third party at the customers expense.

Technical Resource “Drum Classification Codes and Off-specs”: This document is posted in the support center under the Plant Operations Section. The table provides waste class code specification information as well as common off spec codes and the factors used to apply the off-spec code.

System Resource Manifest Drum Viewing Screen Allows user to view facility receiving and tracking information. Items to view Manifest numbers Tracking numbers assigned to the containers Generator signature date Plant receiving date Process codes assigned by the plant Receiving comments entered by plant chemist Container weights Tracking Activity Lab Analytical Results

Click on Plant Processes then Tracking then Manifest Drum Viewing Click on Plant Processes then Tracking then Manifest Drum Viewing. Input your work order number or manifest number then click retrieve. Notes: 1) The system is a little quirky when using the search icons(binoculars). The safe bet is to use the retrieve. 2) A drop down will appear when more than one line is on a manifest. Use the drop down to select the line item info to be viewed. 3) Loads with multiple manifests will display a list of manifests to choose from. 4) Use the Drum Viewing and Lab Results link to drill further into the details.

The Drum Viewing screen displays the most recent data for the tracking number. For example if AG transhipped the waste to another CHI plant then the AG shipping data would be displayed. To view all info use the History link. Itemized tracking activity can be viewed through the Tracking Activity button.

Lab results screen displays facility test results for each tracking number. Required tests vary based on the waste class code of the profile and the facility handling the material. Note: Plant receiving lab results are not necessarily certified and should not be used to generate formal lab reports for customers.