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RCRA Recordkeeping Requirements – All

RCRA Recordkeeping Requirements – All

The hazardous waste regulations of the Resource Conservation and Recovery Act (RCRA) require Large Quantity Generators (LQGs) and Small Quantity Generators (SQGs) of hazardous waste to maintain a copy of certain documents as a record of their compliance.  In a series of article I identified and explained RCRA’s recordkeeping requirements.  The purpose of this article is to serve as a bulletin board for all of those articles.  Much more information on each topic can be found by following the links below.

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The recordkeeping requirements of the USEPA for hazardous waste generators

The USEPA hazardous waste regulations require you to maintain a record of your compliance

LDR Waste Analysis Plans

Land Disposal Restriction Notifications and Certifications

Facility Personnel Training

Manifests

Exception Reports

Hazardous Waste Determination – Test Results and Waste Analysis

 

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Hazardous Waste Determination – Generator Knowledge

Generator Container & Tank Inspection Records

Emergency Responder Agreements

Contingency Plans

Biennial Reports

Export Reports

 

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Determining the Effective Date for Recordkeeping Requirements

The Requirement to Make Records Available to Agency Officials

 What records must be kept by a Conditionally Exempt Small Quantity Generator of hazardous waste (CESQG)?

ANSWER:  A CESQGis not required by RCRA regulations to maintain any records of its compliance.  However, as a practical matter a CESQG may find it to their benefit to maintain at least the following records for at least three (3) years in order to demonstrate that they are indeed a CESQG:

Let me help you to provide Hazardous Waste Personnel training

Have you trained your Facility Personnel on the RCRA Hazardous Waste regulations?

The maintenance of the required records takes time and resources.  Training of your Facility Personnel takes time and resources.  Compliance with the RCRA regulations of the USEPA and your state takes time and resources.  Let me help.  Contact me for a free consultation on your responsibility to provide initial and annual training for your employees who work with or around hazardous waste.