Record-keeping is something we all probably have to do in some capacity, but maybe we don’t particularly enjoy. But when it comes to hazardous waste, record-keeping can mean the difference between safe, legal operating practices versus substantial fines and illegality. Plus, non-compliance in an Environmental Protection Agency (EPA) audit is much worse than taking the few steps to get all your records in order.
Recording of all hazardous waste activities, from deliveries of waste from on-site generators to permitted treatment, storage, or disposal facilities (TSDFs) to the establishment of interim status facilities, are all regulated by the Resource Conservation and Recovery Act (RCRA). The three steps to good record-keeping by EPA standards are as follows:
1. Sign up for an EPA ID number
But before anything can happen legally, your first order of business is to obtain an EPA ID number. This process is actually quite easy. Simply download the form, EPA form 8700-12, then send it off to your regional EPA office for response and confirmation, and you’re finished. Keeping copies of this application and any other notification from the EPA post-applying is also good practice.
Now that you have an EPA ID number, you can start to have your waste transported or sent off to other facilities. The suggested solution and correct bookkeeping of this journey of hazardous materials comes in the form of manifests.
2. Keep up-to-date hazardous waste manifests
A hazardous waste manifest is much the same as any other manifest, a document which ensures accountability and records the enumeration of all materials. The EPA manifest is designed to confirm and verify that all hazardous waste has been delivered to its proper destination (to a site which is allowed to handle waste) and also that no waste has been lost along the way.
In 2005, the uniform manifest was revised by the EPA. It its current incarnation, it is a form with many carbon copies, with each party involved in the operation of moving hazardous waste signing off on the form and taking a copy for their own records.
But President Obama has mandated that by 2015, we should see some form of an e-manifest tracking system to help get away from the relatively less streamlined process of multiple copy manifests.
3. Submit a National Biennial Report
Apart from obtaining an EPA ID number and keeping a database meticulous manifests, the only other thing to you need to worry about to keep in good standing with RCRA’s record keeping law is the National Biennial Report.
Each even-numbered year (this year’s deadline was March 1st , so the next report will not be due until 2016), all Large Quantity Generators (LQG) and Treatment, Storage and Disposal Facilities (TSDFs) must submit a full report of all its hazardous waste activities including, generating, transporting, storing, and disposing going back the previous two years.
Any generators that produce less than 2,200 pounds, or 1,000 kilograms, of hazardous waste per month are federally exempt from the Biennial Report, though the reporting requirements may vary from state-to-state. The report must be filled out on EPA Form 8700-13A, then submitted to the closest EPA regional office. More information can be found in last year’s EPA instructional form here.
All this can seem like a lot to deal with, especially for if you’re a newer or smaller company, so if you have any further concerns call Hazardous Waste Experts at 800-936-2311 or click here to email us.