Weekly Hazardous Waste Inspections
A Brief Overview of What Goes Into Hazardous Waste Weekly Inspections
Any facility that produces a hazardous waste as listed or characterized in 40 CFR 261 is recognized as a hazardous waste generator. There are three categories of generators in EPA regulations: Very Small Quantity Generators (VSQG), Small Quantity Generators (SQG), and Large Quantity Generators (LQG). The monthly quantity of generated hazardous waste determines which category a generator falls into, and thus, which regulations apply.
Small and large quantity generators (SQG, LQG) are required to inspect hazardous waste containers weekly for leaks and deterioration, as noted in 40 CFR 262 – Standards Applicable to Generators of Hazardous Waste. Using a weekly checklist ensures compliance with this requirement and aids in maintaining compliance records.
Below is a list of items required for weekly inspections:
- Name of inspector, date/time, and area/containers inspected
- Are containers properly and clearly labelled? (Should include “Hazardous Waste”, the type of hazard contained, contents, accumulation date.)
- Are containers free of leaks, damage, or corrosion?
- Are there any signs of leaks or spills?
- Are containers tightly closed?
- Are all dates on containers less than 90 days / 180 days / one year (depending on generator category)?
- What is the date on the oldest container? (Or include dates for each container/waste stream.)
- Is there adequate aisle space?
- Is spill response equipment adequate and accessible?
- Is the total volume of wastes stored below the limit for the applicable generator category?
- Are there warning signs present and in good condition?
- Is fire control equipment present?
- Are communication devices present?
Weekly inspections are not federally required for very small quantity generators (VSQG), but it is a best practice to perform inspections regularly. States may have more stringent regulations, so be sure to check your state’s requirements.
For more information about how to calculate your generator status, what records are needed to be maintained, or any other questions related your facility becoming or operating as a hazardous waste generator, feel free to reach out to Carter Venable at Carter@StevensEHS.com to get started
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