USEPA regulations at 40 CFR 261.4(a)(20) provide for a conditional exclusion from management as a solid waste – and therefore as a hazardous waste as well – for hazardous secondary materials used to make zinc fertilizers. You can learn more…
Recordkeeping Requirements of the Generator-Controlled Exclusion at 40 CFR 261.4(a)(23)
40 CFR 261.4(a)(23) is a conditional exclusion from regulation as a solid waste for a hazardous secondary material if its generator complies with the requirements of the exclusion and is generated and reclaimed under one of the following arrangements: Generated…
The RCRA Recordkeeping Requirements in New York
A question from a past attendee of one of my RCRA TRAINING WEBINARS: Hello Daniel, I reviewed the material from our training and see that recordkeeping for Haz Waste is to maintain record for 3 years from last effective date.…
The Recordkeeping Requirements for RCRA Contingency Plans
The RCRA contingency plan is a requirement for large quantity generators of hazardous waste (LQGs) and hazardous waste treatment storage and disposal facilities (TSDFs) pursuant to 40 CFR 265, Subpart D [now 40 CFR 262, subpart M due to the…
Documentation of the Hazardous Waste Determination
In earlier articles I wrote of the regulatory requirement for a facility that generates any solid waste to conduct a hazardous waste determination: The Hazardous Waste Determination and the basis for making the hazardous waste determination. To summarize both articles,…
RCRA Recordkeeping Requirements – Emergency Preparedness & Prevention
The RCRA regulations @ 40 CFR 265, Subpart C – Preparedness and Prevention apply to both Large Quantity Generators and Small Quantity Generators of hazardous waste [via §262.34(a)(4) & §262.34(d)(4), respectively]. A close review of the entire Subpart reveals little in the…
Hazardous Waste Generator Recordkeeping Requirements for Manifests
40 CFR 262.20(a)(1) mandates the use of a manifest (EPA form 8700-22) for a generator who transports or offers for transport a hazardous waste for offsite treatment, storage, or disposal. §262.40(a) requires a generator to keep a copy of the…
Determining the Effective Date for the Retention of Records for Hazardous Waste Generators per the Requirements of RCRA
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…
The Recordkeeping Requirements for Generators of Hazardous Waste: LDR Paperwork
The regulations of the Resource 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…
Making RCRA Records “Available” for State and Federal Inspectors
The requirements for generators of hazardous waste to create documents as a part of compliance with the hazardous waste regulations can be found throughout the RCRA regulations. Similarly, the requirements to maintain a copy of those documents as a record…