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.