DC Velocity - November 2011

▪ Teach employees to recognize “red flags.” Rather than focus on specific products, think in terms of categories that are likely to contain hazardous materials. Employees should know, for example, that all lighting, aerosols, home electronics, cleaning supplies, pet care products, perfumes and nail polishes, and lawn and garden care products—to name just a few—could contain hazardous materials, and they should handle all such returns accordingly.

▪ Pay attention to packaging. Whether at the customer service desk, in the stockroom, or at the shipping dock, employees need to know they can’t randomly toss an assortment of items into any available box, Currie says. Returned consumer goods containing hazardous materials must be properly packaged and secured in accordance with Department of Transportation (DOT) regulations before they’re sent to a warehouse or returns center. Jaffin points out that companies are required by law to report improperly packaged hazmat shipments to DOT. “You have accepted considerable responsibility if you receive and open those shipments,” he warns.

▪ Segregate incompatible merchandise. Train store and stockroom associates to separate products that could produce a dangerous reaction. Currie cites one case where retail associates shipped a drum containing water-activated fumigants together with bottles of cleaning fluids to a returns center. A single leak would have released toxic gas—with potentially fatal consequences for anyone who opened the drum at the warehouse. And don’t package food or consumables with “ORM-D” items—consumer packaged goods classified as hazardous by DOT. Because of the risk of contamination, the consumables may no longer be fit for use and will have to be destroyed.

▪ Be aware that some returned consumer goods must be treated as hazardous waste. Because returned items that are leaking, damaged, or have expired must sometimes be classified as hazardous waste, a hazardous waste program should be in place at the retail location, DC, and reverse logistics operation, recommends Anderson of Inmar. That will require registration as a hazardous waste generator, employee training, a designated hazardous waste storage area, and compliance with a number of specific regulatory requirements.

▪ Send in the experts. Even with training, retail associates who handle customer returns may need additional support to ensure they’re complying with all of the applicable regulations. Some consumer product manufacturers help out by providing approved packaging and instructions for returns, while some power equipment makers send out contractors to clean fuel systems in returned merchandise before it’s shipped anywhere. Consider sending consultants, third-party logistics specialists, or your own in-house experts to conduct audits and train associates at the store level. Or you may decide to hand returns management over to a third party. But don’t assume that all reverse logistics services are handling your materials properly, cautions King of ModusLink. Ask for copies of documented procedures—not just for direct providers, but also for their vendors, he says. ;

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