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