Industries that deal in sensitive or hazardous materials are regularly subject to mandatory record-keeping to meet industry standards and regulatory compliance. The Certificate of Destruction (COD) is a vital document in this process.
This is particularly relevant for aerospace companies and clients in heavily regulated industries.
These companies must demonstrate to clients and regulators that they avoid prosecution and adhere to their commitments to safety and environmental responsibility.
What is a Certificate of Destruction for Aerospace Mutilation, and Why is it Necessary?
In the aerospace industry, where parts are tested with utmost precision and safety, there’s a strict protocol for handling parts at the end of their life. Many components must be destroyed so they can’t be introduced into the market again.
This involves “aerospace mutilation, which is the permanent destruction of end-of-life parts so they can no longer be reused in the market.
What is Aerospace Mutilation?
Compromised parts can threaten the safety and integrity of other aircraft.
According to the FAA and similar regulatory bodies, aerospace components must be disposed of according to safety requirements—enter aerospace mutilation.
After destruction has been completed, a Certificate of Destruction is issued, verifying that all appropriate industry standards and legal requirements have been followed.
This certificate protects the organization and the supply chain from liability by proving everything unusable has been removed.
Why the Certificate of Destruction is Important
The Certificate of Destruction is a legally binding document that helps comply with regulations such as FAA AC 21-43A Appendix D.
The document can later be used as proof of destruction to provide an audit trail showing all parts were destroyed according to the appropriate legal requirements.
In an industry that demands strict safety measures, the COD proves to regulators and other stakeholders that appropriate steps have been taken to ensure the fuel’s safety and compliance.
The Role of Aerospace Recycling Companies
Recycling companies specializing in aerospace materials use aerospace mutilation tools like plasma torches and arc air notching, and they do so with precise attention to compliance.
Why a Certificate of Destruction Matters for Hazardous Waste
Hazardous waste includes electronic waste, chemicals, and other objects that can create severe hazards if not properly disposed of or destroyed.
Certificates of Destruction include evidence that the material has been destroyed under stringent federal and state laws, such as the Resource Conservation and Recovery Act (RCRA).
Compliance and Legal Documentation
Specific and detailed protocols for disposing of hazardous waste exist under state, federal, or local regulations, such as those of the Environmental Protection Agency (EPA).
If an audit occurs, having a Certificate of Destruction proves the materials were processed to the legal standard, which protects companies from fines or penalties.
Environmental Considerations
Hazardous waste can have devastating environmental effects if disposed of incorrectly, affecting soil, water, and air.
When an organization has a COD, it can be seen as going the extra mile to ensure its environmental impact is as minimal as possible.
Data Security
If your hazardous waste includes items with sensitive data—say, old television sets or outdated prototypes—a COD confirms those products have been destroyed and that your data isn’t vulnerable to theft or intrusion.
Detailed Process for Obtaining a Certificate of Destruction
Getting a Certificate of Destruction for hazardous waste involves using a disposal company licensed to dispose of hazardous materials, such as Scrap Gators and their scrap metal removal services.
The process consists of the following steps:
Selecting a Licensed Disposal Company
Picking a disposal company requires some research. A good company will have experience with the type of hazardous waste in question, be certified to handle it, and have the right insurance.
Request Quotes and Ensure Services
Get quotes from more than one company, and be sure each is clear about how they’ll dispose of the remains, what exactly that will cost, and when it will be done.
Verifying Licensing and Expertise
Ensure the company is licensed to accept and treat your type of waste properly. This is especially important for RCRA-compliant operations.
Waste Characterization and Manifesting
After you’ve decided on your disposal company, the next step is to provide information about the waste.
This is done in stages:
1. Characterization
The company will determine the waste’s physical and chemical characteristics. This helps the company ensure the waste is disposed of correctly for the safety of humans and the environment.
The waste generator completes and signs the paperwork. The hauler helps the generator complete all the forms and agreements, such as the Uniform Hazardous Waste Manifest, which tracks the waste from pickup through final disposal.
2. Destruction and Certificate Issuance
The final step in the process is transportation, demolition, and the issuance of the COD:
3. Transportation to Disposal Facility
This involves transporting waste to a certified facility for destruction by incineration, chemical treatment, or recycling.
4 Issuance of the Certificate of Destruction
After the waste has been disposed of, the disposal company issues the COD, which includes information about the waste, disposal facility, method of disposal, and references to the manifest.
5. Custody and Control
The COD is retained as part of the company’s permanent records to demonstrate responsible waste disposal should an audit by a regulating entity or legal action occur.
Legal Requirements for Destruction of Hazardous Waste
The RCRA, a set of laws prescribing a ‘cradle-to-grave’ philosophy, outlines the legal framework for hazardous waste disposal.
Companies must track hazardous materials from the beginning of the manufacturing process to the end of destruction, and everyone involved is held responsible.
Some legal elements include:
Generator Requirements
Identification/Classification: Generators must correctly identify and classify their hazardous waste. Misclassification can result in significant regulatory consequences.
Waste Management Plan: Unlike smaller businesses, those with large quantities of hazardous waste must have a waste management plan. This plan must outline what hazardous waste they generate and how they deal with it, including how it will be handled, stored, and labeled.
Recordkeeping and Manifesting: Anyone who generates or brings any amount of hazardous waste must fill out a ‘hazardous waste manifest’ to track the waste from the point of generation to final disposal, including every transfer, storage, or destruction.
Note that some states have additional requirements. Learn more.
Disposal Facility Standards: Disposal facilities are an important part of the hazardous waste lifecycle and are subject to strict operating standards. Legal requirements include appropriate licensing and permits, documentation, and compliance audits.
Key Information in a Certificate of Destruction
A typical Certificate of Destruction contains comprehensive information documenting the entire disposal process.
This non-exhaustive list includes:
- Identification: Details about the waste generator and disposal company.
- Waste Description and Quantity: A description of the waste type and quantity. This description may also include codes to identify the regulatory classification of the waste.
- Disposal Method and Date: Information on how and when the waste was destroyed.
- Facility Information: Details of the facility where the destruction occurred.
- Manifest Reference Number: This number links the COD with the original waste manifest, ensuring record consistency.
All these details complete the story, showing this hazardous material was handled properly and fully compliant.
Conclusion: Certificates of Destruction for Aerospace Scrap
A COD of destruction demonstrates a commitment to safety, the environment, and responsibility.
Having a good record-keeping system and a COD stored securely demonstrates that an organization is interested in following the regulations and is willing to be held accountable to regulators, customers, and other stakeholders.
Good record-keeping mitigates legal risk. Accurate records also reflect the organization’s role as a good citizen of its industry.
With reliable repeat audits, revised site compliance plans, and the use of licensed disposal companies for storage and disposition, good business practice becomes the hallmark of safe, environmentally responsible record-keeping.
