Environmental Management

Environmental stewardship is the core of our business—our promise to customers, our competitive advantage and our obligation to the communities in which we operate. How we manage potential environmental impacts and opportunities is a critical element of being a sustainable enterprise. In a business as highly regulated as ours, protecting the environment, maintaining compliance and innovating to improve operations requires unwavering focus, expertise, comprehensive systems and internal checks and balances. Our approach has evolved over decades, with a focus on integrating environmental functions into key management systems.

Processes

We have a long track record of both supporting high regulatory standards and striving to go beyond them. Our environmental management approach has led us to undertake the following actions:

Urging the U.S. EPA to revise regulations implementing the RCRA Subtitle D and to establish strong and prescriptive federal standards for managing municipal solid waste (MSW). We supported specific, rigorous, government sanctioned and publicly reviewed standards to ensure environmental protection at all MSW landfills.
Providing comments and technical guidance to federal agencies on the implementation of various environmental laws, including:
- EPA’s potential regulation of liquids management for municipal solid waste landfills under RCRA Subtitle D.
- EPA’s Standards of Performance, Emission Guidelines, and National Emission Standards for Hazardous Air Pollutants for Municipal Solid Waste Landfills.
- EPA’s requirements for generators, transporters, and waste management facilities under the RCRA Hazardous Waste Manifest System. The U.S. Department of Energy’s regulation of the long-term storage and management of elemental mercury.
- EPA’s regulation of PFAS compounds under CERCLA, RCRA, the Clean Water Act, the Clean Air Act, the Safe Drinking Water Act, and the Toxics Release Inventory. EPA’s policies for implementation of the Renewable Fuel Standard.
- EPA’s treatment of biogenic carbon dioxide emissions under Clean Air Act permitting programs.
- EPA’s implementation of its greenhouse gas reporting program and annual inventory of U.S. greenhouse gas emissions and sinks.
- EPA’s comprehensive procurement guideline designations and recovered materials advisory notice recommendations.
- The Federal Motor Carrier Safety Administration’s regulation of electronic logging devices and hours-of-service regulations in the trucking industry.
- The Internal Revenue Service’s regulation of tax credits for carbon oxide sequestration.
- EPA's stormwater Multisector General Permit for industrial sites.
- Department of Energy (DOE) mercury storage fees rule.
- EPA's TSCA fees rule for EPA-Initiated risk evaluations under section 6 of TSCA.
- EPA's regulations on the management of guidance documents.
Innovating beyond compliance. As part of WM’s internal formal performance review, the results of regulatory inspections, internal audits, external audits, and regulatory compliance issues and their precursors are all tracked, managed and remedied as part of the company’s continuous improvement process. Members of senior management, up to and including the Board of Directors, review performance.
Extending the company’s commitment to environmental performance related to events that are not necessarily regulatory in nature but that, nonetheless, are public concerns, such as noise, litter and odors. Such events are tracked, managed and remedied in real time. We also employ best management practices and conduct routine training to eliminate the dissemination of dust from our facilities.
Testing our internal systems to ensure their thoroughness and accuracy. Periodically, we conduct gap analyses of our Environmental Management System against the International Organization for Standardization (ISO) 14001 standards to ensure the sufficiency of our systems for landfills, transfer stations, hauling operations, hazardous waste treatment and disposal facilities and recycling facilities. These systems continue to be evaluated and supplemented as appropriate.
Offering ISO 14001 and ISO 9001 standards certification to all facilities served by WM Sustainability Services (WMSS). View WM’s most recent ISO certifications.
Benchmarking WM’s Environmental Management System (EMS) to ISO standards.
Auditing our operations through an independent environmental audit team that employs nationally recommended compliance audit practices approved by the American Standards for Testing and Materials (ASTM) and the Board of Environmental, Health and Safety certification standards for professional auditors. Nearly all of WM revenues come from operations subject to environmental management systems that are audited.
Testing our facilities to assure stakeholders that our operations protect human health and the environment. Our environmental experts hold a number of patents on innovative monitoring and analysis technologies, and we often provide monitoring data to outside parties to evaluate how our systems are performing.

Environmental Management System (EMS)

Our goal for environmental compliance is simple: zero deviations from regulatory standards, and sound environmental practice. The goal of the EMS is to prevent conditions that could result in violations. If conditions that could result in violations occur, corrective and preventive actions are implemented as quickly as possible.

Our Corporate Environmental Policy establishes the vision for our EMS. The Policy states, in part:

WM is committed to protecting human health and the environment. This commitment is a keystone of all that we do, reflected in the services we provide to customers; the design, operation and long-term maintenance of our facilities; the conditions under which employees work; the implementation of our sustainability initiatives; and our interactions with the communities where we live and do business. We will be responsible stewards of the environment, leaders in sustainability, and will protect the health and well-being of our employees and neighbors. We will work to provide and create public awareness of the importance of environmental stewardship. The following principles are applicable to company operations worldwide:

Protection. Conduct all operations in a manner that protects the environment and WM employees, neighbors and customers. Proactively work to implement procedures and programs that actively audit compliance, identify and manage risks to prevent pollution, reduce emissions and releases, and prevent or reduce other possible adverse consequences from our operations.
Compliance. Comply with all environmental laws and regulations and proactively implement programs and procedures to ensure compliance and promote environmental responsibility.
Sustainability. Practice and promote sustainability through the conservation of nature and the earth’s energy resources and the reuse and recycling of materials that otherwise are wasted.
Communication. All WM employees are responsible for helping the company identify potential threats to human health and the environment from our operations and remedy possible non-compliance with environmental laws and regulations. Suspicion of violations of law or WM’s Core Values of Ethical Conduct and Practices shall be communicated in accordance with the company’s Business Ethics and Compliance Policy and Environmental Reporting and Incident Notification Policy.
Disclosure. WM will provide annual updates on its environmental goals and key indicators and will provide a comprehensive GRI-based sustainability report every two years.
Engagement. WM will seek opportunities to engage with stakeholders on environmental, social and governance issues, and will report on the groups with which we engage.

The company has developed processes, procedures and tools for use in achieving its high standards for environmental performance and compliance. They collectively form the WM Environmental Management System (WM EMS). The company’s operations, across all lines of business, are responsible for implementation and adherence to the WM EMS at each operating location. This applies to all business endeavors in which WM has 50% or more ownership.

Our management will regularly monitor operations and make recommendations to the Board of Directors on programs to continuously improve the environmental performance of the company. Environmental goals and objectives will be established, reviewed and approved during management review. The WM Board of Directors and executive management will regularly monitor the environmental performance to ensure adherence to the principles of this policy across the company.

Our EMS focuses on preventing, correcting and ultimately reducing impacts associated with our operational activities. Specifically, we focus on eliminating:

Environmental impacts. Includes spills or leaks from vehicles, landfill gas impacts on the air or subsurface and releases to surface water or groundwater.
Community impacts. Includes odors, litter, noise, dust and spills or leaks.
Regulatory impacts. Includes regulatory inspection-alleged issues, warning letters, violations and enforcement actions.

We also use several databases, systems and processes designed to help facility managers plan, implement, check and respond to their site-specific environmental requirements.

Legal and Other Requirements

Our EMS tools continually evaluate and determine what regulations, permit conditions and contract requirements apply to facilities. These tools include the following:

CyberRegs. An online source for all state and federal statutes and regulations.
Regulatory outreach. Active involvement by our technical professionals in state and local activities associated with environmental regulation development and policymaking.

WM’s environmental teams work closely with our Legal and Government Affairs departments, and they use the above resources, as well as many others, to ensure that all facilities have access to relevant laws and regulations.

Objectives and Targets

We use indicators to quantify environmental performance, including:

Environmental impacts.
Community environmental concerns and impacts.
Regulatory violations.

Our Environmental Incident Rate (EIR) measures our performance and tracks progress toward these goals at the facility level. The EIR is used to drive continuous environmental improvement on a year-over-year basis.

Roles and Responsibilities

Our EMS relies on our corporate, geographic area and facility-level personnel with job-specific functions, roles and responsibilities for planning, implementing and evaluating the EMS components. The specific departments and personnel involved include the following:

Environmental Protection (EP). Develops environmental policies, tools and training, and provides strategic or technical advice, with the goal of 100% compliance. Oversees environmental performance and ensures environmental impacts and issues are resolved, including correction and prevention.
Corporate Engineering Science: Manages research and engineering science to develop an understanding of the interrelationships between our disposal processes and the environment.
Environmental Engineering (EE): Provides expertise in the planning and design of our facilities to ensure that operational activities have limited environmental impact. Performs annual planning and forecasting of life-of-site costs for our landfills, including Financial Accounting Standard 143 retirement obligations. The engineering and accounting controls exercised during this process are extensive and are subject to controls from section 404 of the Sarbanes-Oxley Act, reviewed annually by independent external auditors.
Air/Landfill Gas Management: Develops and implements the corporate GHG and carbon emissions tracking and reduction strategies, sets policies and standards, and is responsible for the planning and development of air quality and landfill gas management tools.
Groundwater Protection: Provides expertise and direction on groundwater protection programs and ensures that environmental monitoring networks are installed and operating to specifications. Provides laboratory services that ensure accuracy and quality control in the analytical testing of environmental samples.
Laboratory Services: Provides oversight and guidance to the commercial laboratories that support WM’s monitoring programs in order to manage risk associated with the analytical testing of environmental samples. Provides support to all facilities that collect certain routine environmental data.
Waste Approvals: Ensures permit compliance and safe and environmentally sound waste acceptance procedures and controls.
Government Affairs: Monitors and engages with key federal, state and local governmental entities to ensure that we are at the forefront of developing trends and regulations.
Legal: Provides guidance, support and advice to our sites and market areas, monitors compliance trends, and manages the company’s process of analyzing the root cause of any failures.
Site Managers and Frontline Employees: Responsible for all environmental aspects at the site level, with key environmental tasks assigned to appropriately trained local staff.

Training

WM recognizes that to achieve environmental performance goals, employees must possess the knowledge and skills to manage and conduct operations in environmentally responsible ways. Our environmental training targets a range of operational and functional levels within the company. All new employees participate in corporate ethics and compliance training, which includes our company’s standards for environmental practices. Corporate and local staff with responsibility for environmental leadership are trained in the company’s environmental practices. Employees with environmental leadership responsibility are provided training through the following programs:

Talent Central Learning Portal: Environmental Protection Learning Series (EPLS) online modules.Monthly online site management trainings on a different environmental subject each month. Completion is mandatory, and knowledge is tested and tracked.
In-person training sessions: On-site trainings conducted by our field EP and/or operations professionals for facility management and technical staff on environmental and compliance subjects.

In addition, WM has environmental training programs targeting operational and functional levels. Our Environmental Compliance Awareness Program provides mandatory monthly training for frontline employees and managers, covering a different environmental subject each month. Knowledge is tested and tracked at the site level. Monthly topics are aligned between these programs, whenever possible.

Local training is also provided periodically via in-house classroom training, on-the-job training and outsourced training. In addition, staff with responsibilities related to specific environmental requirements for our operations sometimes need job-specific training, which is provided to employees and managers at all WM operations. We have instituted Landfill Greenhouse Gas worksheets that must be completed by all on-site employees, and we offer a Gas Collection and Control System Design and Installation Guidance Manual to ensure landfill employees are using best practices.

Communications

Communicating environmental commitment and performance to our customers, communities, regulators and investors strengthens our ability to be an environmental leader in our industry. Internal communications regarding environmental commitment and performance help create an atmosphere where all employees work toward the common goal of continuous improvement.

We communicate our environmental commitment within the company using the following methods:

WM’s Environmental Incident Alert Notification System gives immediate, company-wide notification of significant environmental or regulatory events—including reportable quantity (RQ) spills, environmental impacts (e.g., stormwater, leachate), alleged violations and enforcement actions.
WM’s CASES Database and Public Commenter Systems provide real-time notification of customer-related environmental issues to site managers for response and resolution.
Environmental performance results, including the following impacts, are tracked monthly and communicated company-wide—and to senior leadership—via the EP Dashboard:
- Environmental impacts such as spills, leaks, gas migration, groundwater contaminant exceedances, certain releases to ambient air and stormwater discharges in excess of applicable standards.
- Regulatory impacts such as alleged violations, inspections and enforcement actions.
- Community impacts such as off-site spills/leaks, odors, noise, pests, mud and litter.
- WM Visor, our intranet system, updates reporting systems to help manage tracking of landfills, tanks, authorized vendors and environmental compliance.
- Overall compliance performance is reported to management, according to the EP reporting structure, via routine activity reports.

We also communicate our environmental efforts with our communities, customers, regulators and investors through other methods, including the following:

WM’s corporate website highlights significant research, environmental awards and unique achievements in environmental management.
Community comments are centrally managed and tracked through response and, if necessary, correction.
Our environmental scientists and professionals present achievements and research at national and international environmental conferences.
Our Corporate Communications department is responsible for communication of environmental issues at the company.
Our local managers support community outreach programs.

Documents and Operational Controls

WM has several internal systems for maintaining documents and records related to the EMS. The location of any particular document or record depends on the specific application, since many of the EMS tools are multiple-purpose programs. The two main internal systems are the following:

WM Visor Environmental Protection Website: Visor is the company’s intranet, with links to all formal corporate environmental policies, standards, documentation and resources, including the EMS, training materials, web-based tracking systems and databases. Visor is available to all company employees and is reviewed and revised on a routine basis to ensure that it is up-to-date and includes the most recent documents.
The SharePoint webpage: used to store and share environment-related documents, guidance, training materials and other electronic resources. All Environmental Program and Technical Managers have access to the SharePoint website. The SharePoint is available for interactive program tracking, including site visits, order tracking, document development, idea development and sharing, and document sharing. The SharePoint page is regularly reviewed and updated.

We have a wide range of environmental databases including the following:

Cycle: The compliance assurance task calendar program for identifying and tracking the completion of site environmental tasks regarding permits, regulations, site plans, policies, etc.
Environmental Reporting System (incident alerts). The repository for reported agency-identified violations (AIVs), environmental exceedances, self-identified concerns and public comments. Corrective and preventive actions are also tracked through this process.
Environmental Enforcement Database (EED): The Legal department’s violation tracking database for tracking significant violations through completion and reporting the results to senior management and corporate governance.
Storage Tank Database: Used to manage aboveground and underground storage tanks, including registrations for insurance purposes.
Applied Landfill Information Analysis System (ALIAS). A relational database used to cross-reference landfill characteristics (e.g., cover, liner, waste type) to monitoring points and results.
EQuIS: Contains our groundwater, surface water and other analytical data provided by contract laboratories. Used for reporting, data integrity and management purposes.
Landfill Gas Management System (LGMS): Houses operational and performance data relating to landfill gas collection and control systems.
PharmE Waste Wizard: Maintains hazardous waste categorization for over 220,000 pharmaceuticals on the market, updated weekly.

In addition to the above, each facility is responsible for maintaining its own operating record, including documents, inspections and reports required by regulation.

Emergency Preparedness and Response

We’re always working to refine and improve the disaster response and preparation plans for our facilities. We maintain an Emergency Situations and Evacuation Plan Policy, which communicates management objectives for addressing emergency situations. Facilities may also be required to maintain specific emergency response plans, including the following:

Hurricane Preparedness Plans and annual simulation exercises.
Disaster Preparedness and Management Plans in areas subject to natural disasters (e.g., tornados, fires, earthquakes), for safe handling of disaster-generated debris.
Spill Prevention Control and Countermeasures (SPCC) Plans for facilities that store certain volumes of petroleum products and are required to prevent, contain and control spills.

Our employees are trained and drilled to comply fully with Emergency Situations and Evacuation Plans, Local Preparedness Plans and Spill Plans.

Monitoring and Measurement

We use the following programs within our EP Dashboard as a multipurpose, integrated system to monitor, measure, report and track environmental aspects and impacts through closure/completion:

Environmental Incidence Rate (EIR):This online system is used to measure, track and report performance across three areas: the environment, our communities and regulations. Our performance goal is continuous year-over-year improvement in EIR performance (Environment, Community and Regulatory).
- Environment: We compile environmental incidents that occur at our operations, including the following:
  - Groundwater impacts that exceed regulatory criteria or that show increasing trends.
  - Stormwater impacts above reportable release levels.
  - Air impacts that include reportable air emissions.
  - Landfill gas impacts registered by perimeter gas probes.
- Community: To underscore the company’s commitment to the communities it serves, WM developed and deploys a public comment management system. When a comment is received, the information necessary for a prompt response and remedy is routed to the closest responsible manager. The manager is empowered to take action, appropriate to the circumstances, and track remedies through to completion.
- Regulatory: Regulatory incidents and, more importantly, their precursors are tracked, managed and recorded for each occurrence as part of the company’s compliance program and continuous improvement process. Lessons learned are shared via the company’s EP Dashboard and program of weekly and monthly reporting. Senior management, including the Board of Directors, is briefed on performance on a regular basis. The position of Chief Compliance Officer exists to elevate the issue of regulatory compliance.

Corrective Action and Preventive Measures

Local EP Managers are responsible for ensuring resolution and prevention of issues identified through the EP Dashboard, EP Toolkit and other environmental database reports. Facility and EP Managers are responsible for ensuring that all identified incidents are closed out completely and correctly. Measures or actions that are not effective are subject to reopening of the incident.

EIR incidents are documented and tracked until all corrective actions and preventive measures are implemented. Performance related to completion of the corrective and preventive measures is tracked via the EP Toolkit.
The public comment management program is the process for addressing environment-related calls from our customers and communities. Environmental comments received at Customer Service Centers are entered into CASES, while calls received directly by the facility can be entered into Public Commenter by the site staff. Any comment requiring corrective action is routed to the local entity for response and resolution. Environment-related comments uploaded into either system are centrally tracked through correction and preventive measure implementation.
The WM Integrity Helpline is our portal to internally identify potential instances of noncompliance with company or regulatory procedures. We communicate to employees that it is available for their use and promote a Speak Up culture wherein when they speak up, we will listen up and follow up. Every inquiry is logged and tracked to ensure that the issue is resolved, up to and including any required corrective actions. The Legal department and EP work together to assess whether the incident has any national implications and to ensure that a lesson learned in one location is rippled across the organization. The Helpline is maintained by a third party where reports can be made anonymously 24 hours a day, seven days a week.

Our facilities are expected to ensure that corrective actions and preventive measures are effective. Environmental issues are not closed out in any of these systems without the concurrence of the EP Manager.

Compliance Audits

WM’s Corporate Compliance Audit Services (CAS) conducts independent environmental, health and safety (EHS) and transportation compliance audits. Each year, the department conducts hundreds of audits at facilities owned, operated or controlled by the company. Audit planning and scope are based on risk assessment principles, including the nature of operations and consideration of emerging regulatory and EHS trends. CAS reports to the Chief Compliance and Ethics Officer and the Board of Directors. Audit practices are in accordance with nationally recommended compliance audit practices approved by the ASTM (2000) and the International Internal Audit Standards Board’s (IIASB) International Standards for the Professional Practice of Internal Auditing (2017).

CAS evaluates and supports improvement of the company’s EHS performance through the following activities:

Conducting systematic, documented and objective evaluations to verify compliance with environmental regulatory requirements.
Assisting the company in evaluating and improving the effectiveness of existing EHS and transportation systems and policies.
Assisting the company and its managers in preventing, detecting, correcting and proactively addressing compliance issues.

CAS processes and procedures include the following:

Assessing risk and selecting facilities to audit.
Training of staff conducting audits.
Developing audit protocol documents.
Planning and conducting audits.
Identifying noncompliant activities.
Resolving audit findings.
Documenting management and retention.
Reviewing and updating program directives and procedures.
Auditing quality control and assurance.
Communicating audit results.

Facility staff use designated programs, such as Dakota Tracer, to document resolution of all audit findings. CAS reviews all findings before they are closed and conducts verification audits to ensure that the finding resolution was effective. CAS communicates the audit results to relevant local and corporate management and follows up to ensure the timely resolution of issues identified through its compliance audits.

As part of our auditing and compliance process, we ensure that we can monitor the final destination of our waste, that no hazardous waste is transported from developed countries to developing countries, and that products sent from developed countries to developing countries for repair or resale are not waste. WM’s electronics recycling division is Responsible Recycling (R2):2013, ISO 9001:2015, ISO 14001:2015 and RIOS:2006 certified.

The Responsible Recycling (R2):2013 Standard requires certified organizations to comply with all applicable import and export laws covering shipments of Focus Materials generated from the processing of electronics in accordance with the Basel Convention and with Section 6 (1) of the Standard, for Reusable Equipment and Components, Tested and Full Function, R2/Ready for Reuse requirements.

WM’s electronics recycling division is audited regularly for compliance to the standards it subscribes, which includes monitoring of final destinations for destruction, recycling, refurbishment, reconditioning and/or resale.

Records

Certain data elements are reported with routine frequency, while others are reported on a non-specified schedule. For details on environmental impacts please see the Non-Compliance Associate with Environmental Impacts section of the ESG Data Center.

Certain groundwater and surface water test data are collected on a routine basis and tied to sampling events specified in operating permits, licenses and applicable permits (usually quarterly or semiannually). These results are housed centrally through our laboratory management program and are reported as they are generated.

Records relating to analytical results, environmental performance elements and compliance assurance tasks are all maintained online within our IT, Legal and/or Environmental Protection departments. Documents and technical resources are available and maintained on our Visor and SharePoint intranet sites, as are training, guidance and standards resources.

Key environmental metrics are reported and compiled on a weekly basis, monitored and reported to senior management monthly, and managed and stored online. Environmental aspects of our business, including notices of violation, are reflected in senior management reporting and through an internal environmental metric system that is provided to senior management and housed in the Environmental Enforcement Database (EED). Landfill gas collection system performance is monitored monthly with metrics designed to detect and correct upsets.

All our facilities must annually certify their compliance with all applicable permits and regulatory requirements through our centralized Compliance Representation Letter process, which is reviewed by senior management.

Our management teams participate in a management review process to determine the level of success in achieving environmental goals. In doing so, they complete the following tasks:

Review environmental policies.
Review WM’s EMS.
Routinely review environmental performance, issues and incidents on the EP Dashboard.
Evaluate corporate and local environmental goals and objectives.
Amend the EMS as needed, including policies, procedures, goals and objectives.

Management review and response to environmental performance measures, incidents and issues are used to drive operational changes and ensure that continuous improvement goals are met. Our Internal Audit department performs compliance evaluations on an ongoing basis.