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By starting the process of bridging the 鈥渒nowledge gap鈥�, HHW managers can develop the best RFP that best meets their communities鈥� program needs.
By Jack Ranney

The 39th Annual Conference was held in September in Austin, TX at the Austin Renaissance Hotel. It was another important opportunity for those in the hazardous waste management field to learn about what others are doing in their collection programs, participate in professional trainings, network, meet up with old and new friends, and have some fun while doing it. I have been involved with NAHMMA since 1996 and I can honestly attest, this organization has been extremely important to my professional development and growth over the past 28 陆 years. In this modern high-tech age, new technologies have enabled us to connect virtually and are a good way to stay in touch, but there is still no replacement for meeting people face-to-face.

Procurement of Services
A topic that is important to all in the hazardous waste management and disposal field is procurement of services. It is the process by which the scope of service, quality of service, and cost of service is defined, and which we ultimately live by (contractually) for the term of a contract. So, it is a process where 鈥渢eamwork鈥� is essential between purchasing departments and departments responsible for managing the HHW (and hazardous waste) collection, management, and disposal activity for their governmental entity. I emphasized 鈥済overnmental entity鈥� when it comes to managing HHW collection activities, as it is predominantly governmental entities that provide that service to residents. HHW and hazardous waste collection programs are typically housed in the solid waste services, environmental services and/or public works departments.

All these departments in a governmental organization, have many other functions to fulfill to meet their primary service functions. And sometimes, HHW programs are of lesser priority for allocating resources. However, this is changing in many communities due, in large part to awareness and public demand.

A common organizational division of responsibilities for developing and managing the procurement process for hazardous waste collection services is for the Purchasing Department to control the process. Government purchasing is typically controlled by public policy and state regulation. This is proven to be true for larger municipalities and county governments. In smaller municipalities and counties, there may not be a Purchasing Department, but purchasing may be the responsibility of the department that is managing the collection program service (e.g. public works, emergency management). And, in rural areas it may be the responsibility of the County Judge. However, generally, the default set of procurement policies is state policy and guidelines.

Managing the Process
Through my experience managing a HHW collection program for a river authority and as an Account Manager for hazardous waste management and disposal service companies, I have observed there can exist 鈥渒nowledge gaps鈥� by both the department that is responsible for implementing the collection program and the purchasing department that manages the procurement process.

It is not uncommon for the program manager (or coordinator) of a collection program that provides periodic one-day collection events to also have other job responsibilities unrelated to the HHW collection program. However, he/she is the team lead to work with the purchasing agent that is responsible for constructing and implementing the procurement process. Also, the other part of the team, the purchasing agent assigned to manage the procurement process, is not trained and fully knowledgeable about the complexities of the hazardous waste management and disposal industry. Communities that have permanent collection programs are fortunate as they may have dedicated trained staff that train and focus just on the HHW service their entity provides. However, 鈥渢eamwork鈥� and bridging 鈥渒nowledge gaps鈥� is a process that also applies to permanent programs.

A primary responsibility of the purchasing agent is to make sure the procurement process is conducted and implemented in accordance with purchasing policies and guidelines. The purchasing agent is often reliant on the collection program manager to provide the background for the scope-of work and service needs of the program in the RFP.

When an RFP is released, the clock is ticking for prospect bidders to review and submit their proposals. Thank goodness for the 鈥淨uestions鈥� period included in formal RFPs! The 鈥淨uestions鈥� period is a date sometime before the due date for bidders to submit questions they may have regarding the scope-of-work, terms and conditions, and other parameters/requirements stipulated in the RFP. It is the opportunity for bidders to address a requirement or parameter in the RFP that is nonconforming to industry standard or a process different from how they deliver services. It is an opportunity for buyers and bidders to get clarification and resolution regarding variabilities in the services requested and how a bidder will respond to variabilities in their proposal.

It may sound presumptuous and one-sided, but hazardous waste management is what hazardous waste management companies do鈥攊t is their specialty. They know the regulations (OSHA, DOT, RCRA, and more) and they spend money on training and compliance, on equipment and supplies, and facilities that are specific to managing and disposing of hazardous wastes. And their operations and delivery of their services has been designed and structured to comply with the different state and federal regulations.

Bridging the Knowledge Gap
Over the course of my career, I have observed RFPs being withdrawn, re-released, and contracts having to be amended or even canceled because of 鈥渒nowledge gaps鈥� or variabilities that existed but were not addressed and resolved beforehand. I have observed communities issue RFPs without an understanding of industry standard pricing and how different chemical wastes are packaged and priced鈥攁 common one is how some government purchasing policies give the highest point score to the lowest cost bid without emphasis to quality of service and compliance history. Yes, communities need to be fiscally prudent, but they also need the knowledge to structure their RPF so that it services their program needs in the safest, compliant, and most cost-effective way.

The intent of this article is not to disparage purchasing staff in any way. Its purpose is to start the process of bridging the 鈥渒nowledge gap鈥�, so they can develop the best RFP that best meets their communities鈥� program needs. Implementing the procurement process for hazardous waste collection and disposal services is cumbersome and the cost is not insignificant. Hazardous waste management is a highly regulated industry. Having a good understanding of how hazardous waste management companies must operate can help purchasing departments craft the best RFP for their program. Webinars designed for purchasing managers and/or staff to learn about hazardous waste management would be a good way for them to learn first-hand, about the activities and industry they may be assigned to craft an RFP or bid for. And there is no better resource for hazardous waste trainings than NAHMMA. | WA

Jack Ranney has an extensive history and experience in the solid waste and hazardous waste industry, having worked in the industry for almost 29 years. In 1993, he was involved in the Solid Waste Project, a regional feasibility study for LCRA鈥檚 electric and water customers to manage municipal solid waste in response to the EPA鈥檚 passage of RCRA Subtitle D. In 1996, Jack became Program Coordinator of the LCRA Household Hazardous Waste Collection and Education Program and also worked with the Texas Commission on Environmental Quality and the Texas Department of Agriculture to implement agricultural pesticide and chemical collections in the LCRA watershed. Jack was the Program Manager for the HHW Collection and Education Program for LCRA and administered the HHW collection program in 10 counties along the Colorado River for approximately 12 years. In 2008, the LCRA HHW collection program ended, and Jack transferred to LCRA鈥檚 Economic Development Department with primary responsibility to assist LCRA鈥檚 electric and water customer communities in developing their own HHW programs. From 2013, Jack worked with PSC Environmental Services as HHW Account Manager servicing governmental HHW and agricultural pesticide waste collection programs for Louisiana, Texas, Arkansas, Oklahoma, New Mexico, Kansas, and Missouri. In 2014, PSC became Stericycle Environmental Solutions, Inc. And subsequently, Jack continued as an HHW Account Manager with Clean Earth Environmental Solutions, Inc. Jack has his own consulting firm, Waste Options Southwest, LLC, and specializes in strategic planning, collection program planning, hazardous waste management. Jack is also on The Board of Directors of The Pesticide Stewardship Alliance. He can be reached at (512) 422-2891 or e-mail at [email protected].