We first distributed this blog in November of 2014, but it has continued to be helpful and useful and wanted to share it with you again! Hazardous waste generators are under constant scrutiny to avoid violating regulations set by RCRA as well as national and state government. In order to help you avoid any potential violations we have developed the following list of 10 steps. If you manage your waste with these ten things in mind you should be able to maintain a safe and compliant workplace.
Containers of hazardous waste in a 90 or 180-day storage area must be marked with an accumulation date. Check that yours are each week during your inspection of the storage area. You could also consider using a log or spreadsheet to track wastes in addition to review of dates during your area inspections.
Remember, “Used oil is defined as any oil that was refined from crude oil or any synthetic oil, and that is used and as a result of such use is contaminated by physical or chemical impurities.” Any container holding used oil must be marked “Used Oil.” Additionally, pipes used to transfer used oil to a UST must be marked “Used Oil.”
Except in the instances of adding or removing waste containers should always remain closed. This means closing and latching funnels, screwing in bungs, using drum rings, and tightening bolts. Remember, if the contents would spill if the container was overturned, then the container is considered open.
Make sure you understand the regulations for universal wastes (things like batteries and used lamps). Properly label the wastes as “Universal Waste Batteries” and “Universal Waste Lamps.” Check your local state regulations as well.
Containers in a 90 or 180-day storage area must be marked with the words “Hazardous Waste” as well as listing: generator name and address, accumulation start date, contents, physical state, and hazardous properties.
Whether you’re a small quantity or large quantity generator, you must have a contingency plan in place. You can help make sure you avoid violations by designating an emergency coordinator, keeping information up to date and on-site, ensuring all required elements are included in your plan, and for LQG’s, document submittals to local authorities.
A hazardous waste reduction plan (often referred to as a waste minimization plan) is required for all hazardous waste generators. To keep yourself compliant make sure you keep a copy on-site, update that copy annually to ensure accuracy, make sure it’s signed by management, and ensure all applicable elements are included.
Utilizing satellite accumulation areas can be very beneficial to hazardous waste generators but it is imperative that all requirements listed in 40CFR are followed. Keep yourself violation free by reviewing and understanding the definition of a satellite accumulation area and by labeling your container once the first drop of hazardous waste is added.
Ensure consistency in your inspections by designating one day a week to perform them. Remember that Monday’s and Friday’s are not typically the best choices since they are often spent catching up from the weekend or readying for the weekend respectively. Have a back-up inspector and make sure that all inspections are documented in an inspection log.
You must make a hazardous waste determination for all wastes generated on your site. You should also make a list of each kind of hazardous waste generated. Determine if any exemptions apply to your wastes and figure out if your wastes are listed or characteristic hazardous wastes. Treat any unknown waste as hazardous until a determination has been made. Document everything and hold on to the documentation.
Learn more about a team member whose career path has allowed him to discover new interests and expand his skillset in areas he already enjoyed.
Learn more about how health and safety is the number one goal for Field Technicians at Heritage.
We’re honored to receive recognition for our support of business and manufacturing communities in Indiana and across the country.
Check out this interview with two Heritage Veterans
Employee spotlight of Senior Lab Technician Kevin Smith and Senior Analyst Sara Lockard
Maintaining a world-class transportation network starts with investing in our people.
A value-adding partnership between Northwestern University & Heritage Environmental that led to a wastestream data model for safe & efficient science.
Learn more about our new rotational development program for aspiring leaders.