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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Not sure of your hazardous waste generator status? |
The USEPA hazardous waste regulations require you to maintain a record of your compliance
Land Disposal Restriction Notifications and Certifications
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
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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:
- Copies of the Uniform Hazardous Waste Manifest (if used) signed by the Designated Facility.
- Documentation of the Hazardous Waste Determination for all solid waste.
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.