Daniels Training Services

Common RCRA Violations at Colleges and Universities

Common RCRA Violations at Colleges and Universities

Colleges and universities are subject to the hazardous waste regulations of the Resource Conservation and Recovery Act (RCRA) the same as any other business within the US.  The regulations of a state with an authorized hazardous waste program may be more strict and more broad than the Federal regulations.  The violations noted below are derived from USEPA Region 1 which includes the New England states.  The information compiled below may be of some use in attaining compliance at your university or college.  It is not, however, meant to be an all-inclusive list and does not provide guidance to comply with applicable State or Federal regulations.

  • Failure to clearly label and mark satellite accumulation containers with the words “hazardous waste” and other words that identify the contents of the containers, such as the chemical name [40 CFR 262.34(a)(3)]
  • Failure to clearly mark and date the period of accumulation for each accumulation container. [40 CFR 262.34(a)(2)]
  • Failure to provide and document initial hazardous waste training. [40 CFR 265.16]
  • Failure to separate or otherwise protect containers of hazardous waste from other containers storing incompatible materials or wastes [40 CFR 265.177(c)]
  • Failure to make hazardous waste determinations. [40 CFR 262.11, 40 CFR 268.7(a), 40 CFR 268.9(a)
  • Failure to accumulate hazardous waste in a closed container except when adding or removing waste. [40 CFR 265.173(a)]
  • Failure to obtain a permit when storing hazardous waste for greater than 90 days. [40 CFR 262.34(a), 270.10]
  • Failure to inspect hazardous waste containers, specifically failure to inspect on a weekly basis. [40 CFR 265.15(a), 40 CFR 265.174]
  • Failure to have an adequate Contingency Plan for new operations. [40 CFR 265.54(c)]
  • Failure to provide secondary containment around hazardous waste container storage areas in an area with a functional floor drain. [40 CFR 264.175 and 264.193]
  • Failure to maintain and operate the facility in a manner to minimize the possibility any planned or unplanned release of hazardous constituents to air, soil, or surface water which could threaten human health or the environment. [40 CFR 265.31]
  • Failure to maintain adequate aisle space to allow the unobstructed movement of personnel or emergency equipment in the container storage areas. [40 CFR 265.35]

Not only is the lack of training a violation in itself, if properly conducted Hazardous Waste Personnel training can help to eliminate the remainder of the above violations.  My Onsite Training is  a great way to meet the RCRA training requirements and to learn what is required to maintain compliance with all of the RCRA regulations.  Please don’t hesitate to contact me for a free training consultation.