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“Spring Clean” Your Compliance Records For Hazardous Waste Management

April 26, 2017

The advent of warm weather induces many of us in to clean and organize our life spaces. We sweep out our garages, return order to our basements, excise barrels of dust bunnies from beneath our beds, wipe under the knickknacks as well as around them, etc.

Unfortunately, the realities of hazardous waste management discourage waiting until April or May to dispose of hazardous waste. An abundance of State and Federal regulations make it imprudent to keep a barrel of spent hazmat hanging around until the next vernal equinox

Nonetheless, it’s telling that the term “spring cleaning” is also used metaphorically for any kind of major organizing effort on the part of a company or individual. Putting paperwork in order prior to an audit or inspection is often described as “doing some spring cleaning.”

So are your papers in order?  Or can you at least quickly find them?

There are core pieces of paperwork an EPA inspector will want to see when he or she visits your site. They should be organized together in a common space: in the same electronic file in the case of digital documents, or in the same filing-cabinet drawer in the case of hardcopies.

Which and what paperwork should you update and organize?

There is required paperwork that is fairly common across the different kinds of businesses and industries that must deal with hazardous waste or chemical disposal. However, different types of enterprises are required to have updated documents that are specific to their hazardous waste management needs. The eight items below provide a place to begin.

  1. Contingency plan for hazardous waste management.

    This paperwork is required of all hazardous waste treatment, storage, and disposal facilities (TSDF). It’s also required of any entity deemed a large quantity generator (LQG) of hazardous waste. Plans need to be clearly articulated, individual personnel must know their respective duties in case of an emergency, and their contact information must be up to date.

  2. Hazardous waste training records for personnel.

    Individual personnel at LGQ entities must complete annual training, and training records for each must be extant for minimally three years subsequent to his or her attrition.

  3. Records of waste determination.

    You must document how you identified something as hazardous waste and what danger it poses. But just as importantly, you should document how you identified something as not being hazardous waste in the event you’re challenged about it. Such records must be extant for three years subsequent to the last treatment, storage, or disposal of a material.

  4. Generator’s biennial report.

    This must be extant for three years after the due date: generally March 4 of even-numbered years.

  5. Hazardous waste manifests.

    These are integral to most hazardous waste inspections. As a hazardous waste generator, you must keep a copy of the manifest signed by the transporter; a confirmation copy of the manifest with the TSDF’s signature must also be kept on file after the waste is accepted by the transporter. Both must be extant for three years.

  6. Land disposal restriction documentation.

    Certain determination and notification records must be kept onsite for three years subsequent to your shipping hazardous waste offsite to be treated before disposal.

  7. Tank and storage area inspection records.

    If hazardous waste is managed in tanks, such tanks must undergo daily inspections, records of which must be extant until the facility closes, along with an engineering assessment of the tank system’s integrity.

  8. Incident reports.

    In the event of an incident that involves your contingency plan, you must keep records of the time, date, and details until your facility closes.

Keeping these documents at-the-ready so that you can quickly present them on demand will facilitate the inspection process and reduce the inevitable angst that comes with an EPA visit. It will also make for a calmer, happier EPA inspector—which has obvious benefits.

Disposal of hazardous waste doesn’t have to be painful.