Daniels Training Services

Hazardous Waste Generator Recordkeeping Requirements for Inspections

Hazardous Waste Generator Recordkeeping Requirements for Inspections

The hazardous waste regulations of the Resource Conservation and Recovery Act (RCRA) require certain generators of hazardous waste (large quantity generators and small quantity generators) to conduct regular inspections of hazardous waste accumulation containers and tanks.  While you may be aware of the inspection requirements, you may not be aware of your responsibility to maintain a record of those inspections.

Required Inspections:
  • Large quantity generator and small quantity generator weekly inspections of hazardous waste accumulation containers (more…)
  • Large quantity generator and small quantity generator daily inspections of hazardous waste accumulation tanks.
Inspections not Required:
  • Hazardous waste in a satellite accumulation container.
  • Hazardous waste at a conditionally exempt small quantity generator.
  • Universal wastes managed in compliance with 40 CFR 273.
  • Used oil managed in compliance with 40 CFR 279.
Required Documentation of Inspections:
  • Large quantity generator daily inspections of hazardous waste accumulation tanks [§265.195(g)].
Documentation of Inspections not Required:
  • Large quantity generator and small quantity generator weekly inspections of hazardous waste accumulation containers.
  • Small quantity generator daily inspections of hazardous waste accumulation tanks.
Required Recordkeeping of Inspections:
  • None.
Recordkeeping of Inspections not Required:
  • Large quantity generator and small quantity generator weekly inspections of hazardous waste accumulation containers.
  • Large quantity generator and small quantity generator daily inspections of hazardous waste accumulation tanks.

As described above, the federal regulations of the USEPA do not require you to document most required inspections (except for tanks at an LQG) and have no requirement at all to maintain a record of those inspections (§265.15(d) does not apply to hazardous waste generators).  However, there are several good reasons why you may wish to document all required inspections and maintain a record for at least three years from the date of completion, including:

  • It’s a good way to ensure compliance with all applicable regulations.
  • Federal or state agency inspectors may not understand this regulation and insist upon you providing records of inspection documentation.
  • Your company may require periodic inspections and record retention.
  • ISO 1400 may require documentation of facility inspections.
  • State regulations may differ from those of the USEPA; documentation and recordkeeping may be required by your state.

Annual training for the Hazardous Waste Personnel of an LQG or SQG is not a recommendation, it’s a requirement.  Contact me to discuss the training requirements under RCRA for hazardous waste generators.