The hazardous waste regulations of the Resource Conservation and Recovery Act (RCRA) require Large Quantity Generators (LQG) and Small Quantity Generators (SQG) of hazardous waste to retain a copy of certain documents as a record of compliance.  While there are slight variations in where and how the records are to be maintained (refer to this article on RCRA’s recordkeeping requirements), there are two points on which the regulations agree:

1. Records must be made available to an agent of the USEPA or an authorized state upon request.
2. Records must be maintained for three (3) years from the effective date of the compliance document.

This article will identify the effective date for record retention of documents generated per the the hazardous waste regulations of the USEPA.  Keep in mind that your State may add additional recordkeeping requirements on top of those identified below. (more…)

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 regulations of the Resources Conservation and Recovery Act applicable to generators of hazardous waste, codified at 40 CFR 262-268 mandate the creation of a variety of reports, inspection logs, notifications, certifications, manifest, records, etc.  In order to demonstrate compliance with these regulations a generator of hazardous waste must maintain a copy of the applicable document as a record.  These records must be provided to an agent of the US EPA or their designee upon request.  You can read more about your responsibility to make these records available to an inspector here:  Making RCRA Records Available for Federal and State Inspectors.

The purpose of this article is to look closely at a single recordkeeping requirement of the US EPA for a generator of hazardous waste.  Since these are the Federal regulations, you will need to check with your State environmental agency in order to confirm compliance. (more…)