Regardless of industry, keeping on top of hazardous waste management is a big responsibility for many businesses. It is necessary to ensure that hazardous waste is being handled properly and that no mistakes are being made in its treatment and disposal. Additionally, it’s also very important to keep all the related paperwork up-to-date and ready to be shown to inspectors from the EPA or other regulatory bodies as needed.
To help business owners and managers maintain compliance, here is a helpful list of eight essential hazardous waste documents that should be readily accessible at all times.
An up-to-date hazardous waste contingency plan.
Businesses that generate significant quantities of hazardous waste are also known as large quantity generators, or LQGs. LQGs and businesses that operate as treatment, storage, and disposal facilities (TSDFs) are required to develop and maintain a hazardous waste contingency plan. This document outlines the procedures that should be followed at the facility in the event of an accident or emergency.
It’s very important that the contingency plan be reviewed regularly to make sure it’s accurate and up-to-date, particularly in terms of the phone numbers and other details of the emergency contacts. In addition, all personnel at the business or facility should be regularly briefed on their responsibilities under the contingency plan.
Records of personnel hazardous waste training.
The Resource Conservation and Recovery Act (or RCRA, the US legislation covering waste management, including hazardous waste) stipulates that personnel working at LQGs and TSDFs must complete hazardous waste training on a yearly basis. To ensure compliance, all training must be documented and records of training kept for a specified length of time. The records of employees who leave the facility must be kept for three years after their date of departure; for current employees, records must be kept as long as the facility is operational.
Records of waste determination.
In order for hazardous waste to be disposed of properly, it must first of all be identified correctly, and this is where waste determination records come in. These records specify what hazardous waste the business handled or generated as well as touchdown what criteria were used to identify the waste as hazardous. Once the waste has been sent for treatment, storage, or disposal, these records should be kept for an additional three years.
It’s important to note that waste that is not identified as hazardous doesn’t require the same level of documentation. However, to help businesses be prepared in the event that an inspector challenges a waste identification, it is a smart industry practice for businesses to document how they determined that certain waste was not hazardous.
Depending on their size, hazardous waste generators are required under the RCRA to submit hazardous waste reports at regular intervals. After the submission deadline, each report should be kept for three more years.
Hazardous waste manifests.
Hazardous waste manifests concern the transportation of hazardous waste from the business or place where it is generated to a transport, storage, or disposal facility. Each stage of the journey must be correctly documented and records carefully kept (typically for three years).
One of the two most important documents is the generator’s copy of the manifest with the transporter’s signature, indicating the receipt of the hazardous waste by the person or company responsible for moving it. The second is the confirmation copy of the manifest with the signature of the TSDF representative, which indicates that the waste was accepted at its final destination.
Documentation regarding Land Disposal Restrictions.
The Land Disposal Restrictions (LDR) program was introduced as part of the 1984 update to the RCRA in order to prevent certain hazardous wastes from being disposed of on land. Under the LDR, these wastes must undergo specific treatment before land disposal can take place to avoid problems like groundwater pollution.
Any hazardous waste shipped off-site by a business must be properly documented through LDR determination records and LDR notifications or certifications. Both of these types of documents must be kept for three years following the date of each waste shipment.
Records of tank and storage inspections.
Businesses that use tanks for hazardous waste management are required to conduct daily tank inspections and to document each inspection. These inspection records must be kept on file until the facility closes, along with an engineer’s assessment of the storage tank system’s integrity.
LQGs are also required to perform inspections of any container storage areas for hazardous waste at the facility on a weekly basis. While documentation of these weekly inspections is not specifically required, most businesses recommend it as an industry best practice.
Reports of hazardous waste incidents.
Any time an incident at a business or facility requires the activation of the contingency plan (described in point one, above), it must be comprehensively documented. Businesses must record the time, date, and details of the incident carefully, and keep that information on file until the facility closes.