A question from a past attendee of one of my – now kaput – Training Seminars on September 8, 2015. I encourage follow-up questions and so he did:
Recently we had an internal audit of our 90 day waste storage area at a LQG site.
The auditor reviewed our weekly inspection logs of the storage room but another portion of that building is where we process waste daily such as adding to the 55 gallon Flammable liquid drum, compacting the solid Flammable waste.
All these smaller waste were collected from our many Satellite accumulation spots scattered all around the facility.
The auditor gave me a finding because we don’t have a weekly inspection log of that “in process” room. Is this a legitimate need?
How specific must my inspection sheet be? I often have a several hundred small bottles of either empty or out dated chems in there and they are processed (combined) daily.
I doubt you would ever be able to see each label let alone have walking distance between each.
My reply later on 9.8.15:
Thank you for contacting me. I’ll do my best to answer your question. If you call me and provide more information, I believe I can be of more assistance.
For information related to the weekly inspections of hazardous waste accumulation areas for an LQG – and SQG – please refer to this article I wrote: Weekly Inspections of Hazardous Waste Storage and Accumulation Areas.
Since your State (Iowa) lacks an authorized hazardous waste program of its own, the Federal rule summarized in the above article will apply.
Periodic inspections (at least weekly) are to be conducted of containers used to accumulate, treat (e.g. compacting), or store hazardous waste. I don’t think this requirement would apply to each individual bottle that you process/combine. Instead, it would apply to the containers – e.g. a 55-gallon drum with a hazardous waste label and date of accumulation – that those bottles are accumulated, treated, or stored in.
Inspections are not required for containers used to accumulate hazardous waste in a Satellite Accumulation Area”.
The inspection need only look for leaking containers and deterioration of containers caused by corrosion. It is not necessary to check the containers are labeled or dated properly, though it may be a good idea to do so.
I hope this helps. Please don’t hesitate to contact me with any other questions.
He acknowledged my reply on 9.11.15, but needed more time to review it thoroughly:
Thank you for your quick response. I will read through it.
Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste
Daniels Training Services