Recordkeeping Requirements for Hazardous Waste Generators

keeping Requirements zardous Waste ators

Generating Hazardous Waste?

Know the Recordkeeping Requirements that must be Followed According to the RCRA.

Introduction

All employers must safeguard the health of individuals exposed to or handling hazardous waste. To instill greater diligence in this regard, the U.S. Environmental Protection Agency (EPA) under the Resource Conservation and Recovery Act (RCRA) has developed and implemented a set of rules and regulations that must be complied with.

Take a look at the summarized table of recordkeeping requirements for LQGs, SQGs, and VSQGs.

What Types of Recordkeeping are Required by the RCRA?

All sizes of waste generators can benefit from keeping proper and detailed records, However, the larger the amounts of hazardous waste being handled, the more stringent the recordkeeping requirements. As such, the RCRA gives detailed guidance on recordkeeping requirements for hazardous waste generator facilities.

Let’s discuss these recordkeeping requirements in detail:

1. Employee training records

Hazardous waste personnel at LQGs must receive initial and annual re-training, as per th regulations (262.17(a)(7)(iv)), and these training sessions must be documented.

According to 40 CFR Part 262.17(a)(7)(v), the following records pertaining to training mus be maintained by large quantity generators:

Job titles for positions related to hazardous waste.

Names of employees holding these positions.

Written job descriptions with specific information.

Written descriptions of the type and amount of training provided.

Documentation confirming successful completion of the training, such as a certificat of training.

2. Waste classification records

Maintaining complete and accurate waste determination records is crucial to keep track o the composition of the waste, its origin, applicable treatment standards, and potentia exclusions.

According to 40 CFR Part 262.11(f), the following details must be recorded about the wast determination process:

Results of any tests, sampling, analyses, or other determinations.

Documentation of the methods used for the tests, sampling, analyses, etc.

Records showing the process that generated the waste.

The waste's composition and properties. All relevant waste codes, such as D001, D002, F003, etc.

3. Hazardous waste manifests

In the United States, the Uniform Hazardous Waste Manifest is utilized as a means o monitoring the transportation of hazardous waste. Once a generator has received signed copy from the receiving facility (i.e., a treatment, storage, and disposal facilitie (TSDF)), that particular copy must be preserved as a record for a minimum of thre years from the date on which the waste was accepted by the initial transporter. To align with the increasingly tech-savvy world and transition to paperless systems an processes, the EPA launched the electronic manifest (e-Manifest) option for hazardou waste generators on June 30, 2018. For more information about the e-manifest systems, click here.

4. Hazardous waste contingency plan

Large quantity generators are required to have an RCRA contingency plan to ensure tha emergency responders and personnel have access to accurate and current information t guide their emergency response efforts. Additionally, LQGs must create a quick referenc guide for their contingency plan that includes eight (8) specific elements. The regulations governing the purpose, content, and distribution of written contingenc plans can be found in 40 CFR Part 262, Subpart M.

5. Hazardous Waste Incident Reports

If an incident involving hazardous waste necessitates the activation of th contingency plan, the generator is required to document the event's date, time, an specifics.

This incident report should include the following details:

Name, address, and telephone number of the generator.

Date, time, and type of incident (e.g., fire, explosion).

Name and quantity of the hazardous material(s) involved.

Information about injuries, if any.

An assessment of actual or potential hazards, where applicable.

Estimated quantity and disposition of the recovered material resulting from the incident.

6. Land Disposal Restrictions (LDR) Documentation

The RCRA regulations establish a hazardous waste management system from the poin of generation to final disposal, known as cradle-to-grave. Even after the hazardou waste is disposed of, records pertaining to compliance with land disposal restriction must be retained. Hazardous waste generators are required to keep copies of LDR related records for a minimum of three years after the waste is sent for treatmen storage, or disposal.

The Land Ban Form, Compliance Certifications, One-time Notice to File, and Wast Analysis Plans are some of the documents that must be prepared by hazardous wast generators. For more information about these LDR recordkeeping documents, refer to 40 CFR Part 268.7(a).

7. Records for Tank and Central Storage Area Inspections

Hazardous waste generators are required to regularly inspect the tank and centra storage areas as per the 40 CFR Parts 262 and 265. The regulations also mandat recordkeeping of the daily tank inspections.

The facility should retain tank inspection records until it ceases operation. Additionally according to 40 CFR Parts 265.191(a) and 192(a) and (g), LQGs are required to keep a engineer's evaluation of the storage tank system's integrity until the facility closes.

8. The Biennial Report

According to Federal hazardous waste regulations, LQGs are required to submit a Biennial Report every even-numbered year (2024, 2026, etc.) by March 1st. This report must detail the type, quantity, and disposition of hazardous waste(s) generated or stored during the previous year.

As part of the Biennial Report (EPA Form 8700-13A/B), generators are required to provide specific details, such as:

The EPA ID number of the facility,

The name and address of the facility,

The quantity and type of hazardous waste generated, and

Whether the hazardous waste was sent for recycling, treatment, storage, or disposal.

Training Requirements According to the RCRA

While recordkeeping is important when generating hazardous waste, equally important is the need to provide training to employees and other workers involved in handling hazardous waste in organizations across all types of industries that produce hazardous waste. Thus, employers must provide RCRA initial and annual refresher training to workers in their facilities to comply with regulations and protect the health of workers. Additionally, any organization involved in the treatment, storage, and disposal of hazardous waste must train employees according to the HAZWOPER standards.

Thank You

For your attention!