Preparing For Your Facility’s Hazardous Waste Inspection
May 24, 2019

Going through a hazardous waste inspection should always be on your mind because you should always be preparing and conducting proper waste management in your facility. When are aware of and following all the relevant waste management disposal rules, there will be far less to worry about when it’s time for an inspection.

When you are not prepared for an inspection, it is likely you will be facing fines and other punitive actions for each violation found by the inspector. There are ways to prepare your facility for a hazardous waste inspection, so you don’t have to worry about these penalties.

How to Prepare for the Inspection

In most cases, you are not informed when an inspection is going to happen. Generally, the inspector simply shows up and asks for the person in charge to alert you the inspection is being done that day. Since these inspections can happen without any warning, you want to be prepared.

One of the main ways to remain prepared is to make sure you and all staff members are aware of the relevant rules and regulations assigned to your hazardous waste materials. Your staff must also be made aware of the importance of following those regulations and rules as their actions will reflect on your inspection and determine if you pass or are fined.

Create a waste management plan after you’ve researched how each of your materials should be handled. This plan should be reviewed with each employee, and you should also post the information in a visible area as a constant reminder for each staff member to follow the rules and use the proper containers.

Educate Your Employees about Hazardous Waste Handling

If your employees are not appropriately educated and trained on how to handle hazardous waste materials, it will be nearly impossible to pass an inspection. If your staff does not know how to label, store, transport, or dispose of hazardous waste materials, they cannot be expected to follow the necessary regulations and rules.

What is Considered Hazardous Wastes?

It does not matter which industry your business is in; different categories relate to the waste your company generates. You and your employees need to understand these categories and how your particular waste will need to be transported, contained, treated, and stored before it is ready for disposal. One main category to be aware of is the RCRA hazardous waste.

Resource Conservation And Recovery Act (RCRA) was placed into legislation in 1976. This act is a federal law which created regulations and rules for the proper and safe disposal of solid wastes or any waste designated as hazardous. It also outlines how to identify dangerous wastes with codes in a standard manner correctly.

The codes established ensure anyone dealing with this form of waste deals with it properly, including the industry producing it and their employees. Everyone handling hazardous waste should know the coding system, so they immediately know the protocol for disposing of it properly. When this coding system is followed at all times, your facility will be prepared for a hazardous waste inspection.

The goals of the RCRA are to improve rules surrounding hazardous waste disposal or any other form of waste. It has been set up to protect people who come into contact with these forms of waste and protect the environment from improperly disposed of hazardous materials. It is also designed to reduce the amount of waste generated by using source reduction and recycling.

What are the RCRA Codes?

To make sure the system works in all areas, the RCRA codes are universal so there is a reduced chance of improper handling. It is a numbered system to eliminate any uncertainity about what is being handled. When you know and use these codes with either hazardous or non-hazardous materials, it is less likely your facility will conduct improper protocol and therefore be in compliance when your hazardous waste inspection occurs.

A few of the codes used are:

  • DOO1 which covers flammable liquids. This code includes any material with a flash point that is capable of causing damage when exposed to a certain level of heat.
  • DOO2 is the code for corrosive materials.
  • DOO3 is the code used for reactive materials.

If your business is in the industry which creates hazardous wastes, it is subject to these regulations and rules. Some examples include; if you manufacture steel, its surface has to be prepped by washing it with specific chemicals, and these chemicals are corrosive. If you use chlorinated solvents or paints, these are also considered hazardous wastes.

An industry using wood often uses flammable materials which are considered hazardous by RCRA standards. Veterinarian offices, hospitals, doctor clinics or other medical-related industries also work with hazardous materials such as chemotherapy waste, expired medications, materials containing blood, and more.

It does not matter what the size of your business is; if it creates hazardous materials, it is subject to RCRA waste compliance. When your hazardous waste inspection happens, you have to prove this compliance with the inspector.

Proper Hazardous Waste Manifest is Important

A large part of proving your compliance during your hazardous waste inspection is having a correctly filled out and stored hazardous waste manifest. This manifest will be your proof of having complied with all aspects of the law when your hazardous waste was transported away from your facility. When you want to prove to the inspector that your facility complies, the manifest will be your biggest asset.

The inspector will want to see your hazardous waste manifest; possibly for the past two years. You need to have these documents on-site at your facility, with either electronic copies or hard copies. No matter which filing system you use, these documents have to be ready to show at a moment’s notice when your hazardous waste inspection happens.

When providing the inspector with the manifest, you must make sure the party who has signed the documents has had the proper training and is authorized to sign the manifest.

Why is the Manifest Important?

The main reason the manifest is necessary is that it is a federally required document. The DOT (Department of Transportation) and EPA (Environmental Protection Agency) requires every shipment of hazardous waste to be accompanied by this essential piece of paper. Without a proper manifest, it is sure you will not pass the hazardous waste inspection.

There was a lot of confusion with manifests in earlier years as each state had their own version which was different than the EPA’s version. Due to this confusion, there is now one standardized form, and every generator of hazardous waste uses the same manifest with the same required information listed on it.

When you have a hazardous waste inspection, you will be required to have the proper records for all your manifests. These are your proof that you are following protocol with your shipping of generated wastes and that they are in the correct timeframe. For example; if you are a large quantity generator of hazardous material, you have to ship it out every ninety days without exception. You must have the paperwork to prove you are complying with this law.

If you do not have the proper paperwork, two things can happen:

  1. After a lot of hassle and time, you will have to track down copies of your manifests.
  2. You cannot provide the necessary manifests and therefore, have no way of proving your compliance. This scenario will most likely cause you some severe penalties including steep fines.

When it comes to being prepared for a hazardous waste inspection, having your manifests adequately filled out and ready to show is one of your best chances of proving compliance of laws and regulations.

Hazardous Waste Inspection Requires Properly Filled Out Manifests

It won’t be enough to have your manifests accessible; they must also be filled out correctly. This rule is especially crucial for the transport company you are using and the receiving facility. It could become a dangerous situation if your manifests are not filled out correctly.

When manifests are not properly filled out, it could lead to materials that are not meant to be close to each other, ending up in close proximity of one another. A dangerous protocol could also be employed should there be an accident while the material is being transported, and the first responders use water on a material that would react negatively to it.

The receiving facility must also know the correct information about the hazardous waste they are receiving. The manifest includes all relevant information and could save lives should an emergency occur regarding the material.

EPA Generator Status and your Hazardous Waste Inspection

For your facility to be in full compliance with hazardous waste regulations, you must be following the rules based on your EPA generator status. If your facility is a small quantity generator, you will have different rules, timeframes, and fees that will apply versus a large quantity generator.

The dates of your shipments listed on your manifests have to correlate to the length of time you are allowed to store hazardous waste materials at your facility.

A generator is considered to be any person who creates hazardous waste as outlined under part 261 of title 40 of the CFR (Code of Federal Regulations). There are three categories of generators under these regulations:

  • Very small quantity generate 100 kilograms or less per month
  • Small quantity generate more than 100 kilograms, but less than 1,000 kilograms of hazardous waste material
  • Large quality generate 1,000 kilograms per month or more hazardous waste material

A State or Federal Hazardous Waste Inspection

A federal hazardous waste inspection is less common than a state inspection. Federal inspections are still possible with your facility and happen much more often with large companies. Whether you are a small car repair service or giant manufacturer, it is imperative you and your employees operate every day as if an inspector will come into your facility at any minute.

Generally, an inspector will allow you time to address and fix any violations with either a federal or state inspection. If the issues are still present on the next inspection, you will not be given the same courtesy and may face stricter penalties. If you continue to fail inspections with no proof or evidence of your compliance with rules and regulations, you will increase your fines and penalties. Your best solution to being prepared for your hazardous waste inspection is always to be prepared by following all the laws every day and keeping all documentation current and available.

Ask the Experts for Help

You are required to follow a lot of rules and regulations when handling and disposing of hazardous waste materials. If you are overwhelmed or concerned about a hazardous waste inspection, talk to the experts at Environmental Marketing Services. They can help you decipher all the necessary laws and help to make sure your facility is complying with all state and federal regulations and rules.

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