Hazardous Waste Inspections

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The Importance of Managing Hazardous Waste

Managing an industrial facility’s hazard waste is an important part of industrial, environmental compliance.  Hazardous waste requires “Cradle to Grave” management, this includes : the Generator (the industrial facility) to the Transporter to the Treatment/Storage/Disposal Facility (TSDF)

There are several different types of inspections involving hazardous waste:

  1. Planned Inspections to evaluate certain industry types (Small quantity generators or Large quantity generators)
  2. Complaint Inspections
  3. EPA Inspections

Inspectors typically examine used oil waste, hazardous waste and universal waste.   

How to be prepared for a Hazardous Waste Inspection:

  1. Ensure all wastes have been evaluated
  2. Be sure Hazardous Waste, Used Oil and Universal Waste is properly managed
  3. Maintain emergency response and communication equipment
  4. Be sure hazardous waste-related documents are available (ie. manifests, inspection logs, personnel training records, contingency plan, etc.)

 Common  Hazardous Waste Violations are:

  • Failure to have waste evaluated
  • Unlawful treatment, storage and disposal of hazardous waste
  • Waste incompatibility
  • Hazardous Waste container management is poor, for example: no labeling, failure to maintain records, failure to record accumulation start dates, containers are open, poor container condition, improper aisle space
  • Incorrect packaging and labeling of universal waste
  • Improper used oil labeling or releases
  • Manifests are improperly completed and lack of ‘return to generator’ copy
  • Container inspections and emergency equipment inspections not completed
  • Personnel training is incomplete (lack of job titles, job descriptions and type and frequency of training. Initial and annual refresher training required.)
  • Contingency plan not updated to reflect changes to facility or personnel

 After your EPA Hazardous Waste Inspection:

The company will receive a compliance letter or a notice of violation letter (NOV).  The Notice of Violation will describe the violations, how to correct them and a time frame for correction.  Respond in a timely manner so the company is not turned in for enforcement action is important.  Turn-Key Environmental can help.  Call us at 937-335-8807.

 

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