Top Ten Hazardous Waste Generator Violations (And How to Avoid Them): Part 2

With the start of the new year, we return to the Top 10 Hazardous Waste Violations (And How to Avoid Them) written by Patty Smith, CHMM (Certified Hazardous Materials Manager). We covered numbers 10, 9, and 8 a few weeks ago and this week we will look at 7, 6, and 5. So, without further ado:

7. Contingency Planning Violations

Small Quantity Generator Requirements:

1.) Designate an emergency coordinator and post contact information.

2.) Post the location of emergency equipment.

3.) Post emergency telephone numbers.

4.) Ensure employees are familiar with emergency procedures.

Large Quantity Generator Requirements:

1.) Written plan on-site and up to date.

2.) List name, address, phone number (home and office) for designated emergency coordinator.

3.) Submit to local authorities.

        AVOID this by:

1.) Designate an emergency coordinator.

2.) Keep information up to date and on-site.

3.) Ensure all required elements are included.

4.) For LQG’s, document submittals to local authorities.

6. Satellite Accumulation Area (SAA) Labeling Violations

Either with “hazardous waste” OR Words describing the container contents

AVOID this by:

1.) Review and understand the definition of a satellite accumulation area.

2.) Label your container once the first droop of hazardous waste is added to the container.

5. Storage Area Labeling

Containers in a 90 or 180-day storage area must be marked with the words “Hazardous Waste”

AVOID this by:

1.) Once 55-gallons of hazardous waste or 1 quart of acute hazardous waste is exceeded at the satellite accumulation area, storage area labeling requirements apply after three days.

2.) Ensure all hazardous waste containers in the storage are marked “Hazardous Waste” during the weekly inspections.