Inherently ill‐defined nature of waste: Fatal outdoor poisoning of hazmat waste collection driver ‐ lessons learned

The paper examines the fatal poisoning of a vacuum truck driver who inadvertently mixed sulfuric and formic acid waste, which reacted to produce carbon monoxide gas in the truck's tank. The case highlights multiple systemic issues in the chemical waste disposal industry which may lead to repeat accidents. The paper argues that an ill‐defined composition is an intrinsic property of any waste. Therefore, the guiding safety principle should be to avoid mixing and minimize manual handling to the widest extent possible. Transport for disposal of hazmat waste in non‐conforming 1000‐L pallet tanks presents two unattractive options: (a) A vacuum truck is a simple and cost‐effective solution but entails chemical reactivity hazards upon mixing. (b) A 1:1 transfer of the contents to new compliant containers avoids mixing hazards but introduces manual handling hazards. The option of placing the pallet tank inside another approved enclosure appears unavailable in practice. Currently, the overall best option in many cases may be to transport the waste in the formally non‐compliant pallet tanks, by having guidelines for when and how to relax compliance requirements. The paper argues that the current ADR regulatory regime and the hazmat disposal industry offer insufficient support in making safer options available.