RCRA Housekeeping–Hazardous Waste Determinations
EPA and state inspectors conducting inspections of manufacturing and industrial facilities will easily issue a citation if the facility has not stored and managed its hazardous wastes after making a waste determination. To keep the inspectors at bay, make sure your facility has done the following:
- • Identify if it is a listed hazwaste. Use process knowledge, MSDS sheets, or lab analysis to determine a waste’s toxic characteristics.
- Mark each hazwaste container to indicate the type of waste inside.
- Label waste accumulation dates to make sure you ship wastes within the 90- or 180-day storage limits
- Create aisle space so inspectors can quickly and easily check on the barrels in the back
- Educate employees about hazardous so they don’t smoke near a low flash-point solvent waste.
- Keep waste containers covered to prevent spills and overflows.
- Have working emergency gear nearby that can be easily reached