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 way of a requirement for documentation or recordkeeping.  The one place where a document is mentioned, “…the operating record…” is in §265.37(b), more on that later.  You may, however, wish to create documents and keep records of certain activities required by the Subpart in order to demonstrate compliance with the regulations and to fulfill the wishes of the USEPA.  This will include Testing and Maintenance of Equipment (§265.33) and Arrangements With Local Authorities (§265.37). (more…)

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 signed manifest as a record for three (3) years. (more…)

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 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 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.

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This article:  Land Disposal Restriction (LDR or LandBan) paperwork (more…)

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 are spread throughout the hazardous waste regulations, typically in proximity to the regulation that mandates the document.

The purpose of this article is not to explain the recordkeeping requirements for specific paperwork provisions of RCRA, that will be addressed later.  Instead this article will focus on answering a question I hear often in my public training seminars is something like, “I know I have to maintain records and make them available during an inspection, but how quickly must I provide them?  Is 15 minutes too long?  What about later that day, or the next if no one can locate the documents during the inspection?  Will I face fines if I am cooperative but simply cannot locate the documents during the inspection?”

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