Hazardous Waste InspectionsHazardous Waste Inspections

There are several different types of hazardous waste inspections involving :

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

Inspectors look at Used Oil waste, hazardous waste and universal waste.   Hazardous Waste requires “Cradle to Grave” Management:

Generator è Transporter èTreatment/Storage/Disposal Facility (TSDF)

What Happens During a Hazardous Waste Inspection? 

  1. Entrance Meeting (go over purpose of the inspection, process description and documents to be reviewed)
  2. Facility Walk Through (looking at process operations, waste generation points, waste accumulation areas, and emergency equipment)
  3. Records review (waste evaluation information, Manifests/LDR forms, Inspection logs, personnel training records and contingency plan)
  4. Exit Meeting (discuss compliance or violations found, measures to correct violations, areas requiring further information and compliance assistance information)

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 Violations are:

  • Failure to have waste evaluated
  • Unlawful treatment, storage and disposal of hazardous waste
  • Waste incompatibility
  • Hazardous Waste container management is poor (no labeling, failure to records 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 the 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 timeframe for correction.  Respond in a timely manner so the company is not turned in for enforcement action.