You may think you know everything there is to know about the USEPA regulations for the inspection of hazardous waste containers – and maybe you do – but you may just learn something from the regulatory requirements I’ve assembled below.

Note: the information in this article reflects changes to the regulations made by the Generator Improvements Rule.

1. Both large quantity generators (LQG) and small quantity generators (SQG) must conduct weekly inspections.  The very small quantity generator (VSGQ, formerly the conditionally exempt small quantity generator or CESQG) has no requirement for inspections.

• LQG at 40 CFR 262.17(a)(1)(v).  SQG at 40 CFR 262.16(b)(2)(iv)
• FAQ: What is a central accumulation area?
• Everything About the Generator Improvements Rule

2.  Hazardous waste containers accumulated in a satellite accumulation area (SAA) do not require weekly inspections.

3.  Federal regulations of the USEPA for the management of universal waste and used oil do not include a requirement to conduct inspections of any kind.

• The Universal Waste Option for the Management of Hazardous Waste
• Management Options for Used Oil

4.  “Weekly” is not defined in the Federal regulations of the USEPA.  Does it mean every seven days? Once per calendar week? If a clear answer exists it will come from your state.  Since states with an authorized hazardous waste program may make their regulations more stringent and more broad than those of the USEPA, many states strictly enforce a ‘no more than seven days apart” policy for weekly inspections.  For others one inspection per calendar week will suffice (e.g., Minnesota and Alabama).

• State Authorization of RCRA Regulations
• Check with your state to determine its interpretation – and enforcement – of weekly inspections.

5.  Weekly inspections are required solely for hazardous waste containers in a central accumulation area (CAA).  Hazardous waste accumulated in other accumulation units at a generator are subject to different inspection requirements.

• The Four Hazardous Waste Accumulation Units

6.  During an inspection USEPA regulations mandate a LQG or SQG look for exactly two things:

• Leaking containers, and;
• deterioration of containers caused by corrosion or other factors.

And that’s it!  At least under the Federal regulations; your state may require more.  And, you may find it a good practice to check other compliance issues (e.g. the labeling of hazardous waste containers)

7.  Remedial action is required if deterioration or leaks are detected.  Reference is made to the applicable regulations (§262.17(a)(1)(ii) for LQG and §262.16(b)(2)(i) for SQG) for the required remedial action.  Remedial actions are:

• Immediately transfer the hazardous waste to a container in good condition, or;
• immediately manage the waste in some other way that complies with the applicable (SQG or LQG) regulations (e.g. transfer the waste to another hazardous waste accumulation unit).

8.  Federal regulations of the USEPA do not require the generator to document the results of weekly inspections (this requirement was proposed but not adopted under the Generator Improvements Rule).  States with an authorized hazardous waste program may require a log of inspections conducted, and/or a record of the results of the inspection, and also maintenance of a document as a record.

• Read how USEPA proposed – but did not finalize – a requirement for generators to keep a record of weekly inspections.

Make certain as a generator of hazardous waste you conduct the weekly inspections required by the USEPA.  But in addition you must also determine the specific requirements of your state to ensure complete compliance.  And of course, contact me if you require training for Hazardous Waste Personnel.