Recordkeeping Requirements for Hazardous Waste Generators

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Recordkeeping Requirements
for Hazardous Waste Generators
Generating Hazardous Waste? Know the
Recordkeeping Requirements that must be Followed
According to the RCRA.
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Introduction
All employers must safeguard the health of
individuals exposed to or handling hazardous
waste. To instill greater diligence in this
regard, the U.S. Environmental Protection Agency
(EPA) under the Resource Conservation and
Recovery Act (RCRA) has developed and
implemented a set of rules and regulations that
must be complied with. Take a look at the
summarized table of recordkeeping requirements
for LQGs, SQGs, and VSQGs.
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What Types of Recordkeeping are Required by the
RCRA?
All sizes of waste generators can benefit from
keeping proper and detailed records, However,
the larger the amounts of hazardous waste being
handled, the more stringent the recordkeeping
requirements. As such, the RCRA gives detailed
guidance on recordkeeping requirements for
hazardous waste generator facilities. Lets
discuss these recordkeeping requirements in
detail
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1. Employee training records
Hazardous waste personnel at LQGs must receive
initial and annual re-training, as per the
regulations (262.17(a)(7)(iv)), and these
training sessions must be documented. According
to 40 CFR Part 262.17(a)(7)(v), the following
records pertaining to training must be
maintained by large quantity generators Job
titles for positions related to hazardous
waste. Names of employees holding these
positions. Written job descriptions with
specific information. Written descriptions of the
type and amount of training provided. Documentatio
n confirming successful completion of the
training, such as a certificate of training.
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2. Waste classification records
Maintaining complete and accurate waste
determination records is crucial to keep track of
the composition of the waste, its origin,
applicable treatment standards, and potential
exclusions. According to 40 CFR Part 262.11(f),
the following details must be recorded about the
waste determination process Results of any
tests, sampling, analyses, or other
determinations. Documentation of the methods used
for the tests, sampling, analyses, etc. Records
showing the process that generated the waste. The
waste's composition and properties. All relevant
waste codes, such as D001, D002, F003, etc.
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3. Hazardous waste manifests
In the United States, the Uniform Hazardous Waste
Manifest is utilized as a means of monitoring
the transportation of hazardous waste. Once a
generator has received a signed copy from the
receiving facility (i.e., a treatment, storage,
and disposal facilities (TSDF)), that particular
copy must be preserved as a record for a minimum
of three years from the date on which the waste
was accepted by the initial transporter. To
align with the increasingly tech-savvy world and
transition to paperless systems and processes,
the EPA launched the electronic manifest
(e-Manifest) option for hazardous waste
generators on June 30, 2018. For more information
about the e-manifest systems, click here.
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4. Hazardous waste contingency plan
Large quantity generators are required to have an
RCRA contingency plan to ensure that emergency
responders and personnel have access to accurate
and current information to guide their emergency
response efforts. Additionally, LQGs must create
a quick reference guide for their contingency
plan that includes eight (8) specific
elements. The regulations governing the purpose,
content, and distribution of written contingency
plans can be found in 40 CFR Part 262, Subpart M.
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5. Hazardous Waste Incident Reports
If an incident involving hazardous waste
necessitates the activation of the contingency
plan, the generator is required to document the
event's date, time, and specifics. This incident
report should include the following details
Name, address, and telephone number of the
generator. Date, time, and type of incident
(e.g., fire, explosion). Name and quantity of the
hazardous material(s) involved. Information
about injuries, if any. An assessment of actual
or potential hazards, where applicable. Estimated
quantity and disposition of the recovered
material resulting from the incident.
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6. Land Disposal Restrictions (LDR) Documentation
The RCRA regulations establish a hazardous waste
management system from the point of generation
to final disposal, known as cradle-to-grave. Even
after the hazardous waste is disposed of,
records pertaining to compliance with land
disposal restrictions must be retained.
Hazardous waste generators are required to keep
copies of LDR- related records for a minimum of
three years after the waste is sent for
treatment, storage, or disposal. The Land Ban
Form, Compliance Certifications, One-time Notice
to File, and Waste Analysis Plans are some of
the documents that must be prepared by hazardous
waste generators. For more information about
these LDR recordkeeping documents, refer to 40
CFR Part 268.7(a).
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7. Records for Tank and Central Storage Area
Inspections
Hazardous waste generators are required to
regularly inspect the tank and central storage
areas as per the 40 CFR Parts 262 and 265. The
regulations also mandate recordkeeping of the
daily tank inspections. The facility should
retain tank inspection records until it ceases
operation. Additionally, according to 40 CFR
Parts 265.191(a) and 192(a) and (g), LQGs are
required to keep an engineer's evaluation of the
storage tank system's integrity until the
facility closes.
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8. The Biennial Report
According to Federal hazardous waste regulations,
LQGs are required to submit a Biennial Report
every even-numbered year (2024, 2026, etc.) by
March 1st. This report must detail the type,
quantity, and disposition of hazardous waste(s)
generated or stored during the previous year. As
part of the Biennial Report (EPA Form
8700-13A/B), generators are required to provide
specific details, such as The EPA ID number of
the facility, The name and address of the
facility, The quantity and type of hazardous
waste generated, and Whether the hazardous waste
was sent for recycling, treatment, storage, or
disposal.
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Training Requirements According to the RCRA
While recordkeeping is important when generating
hazardous waste, equally important is the need
to provide training to employees and other
workers involved in handling hazardous waste in
organizations across all types of industries
that produce hazardous waste. Thus, employers
must provide RCRA initial and annual refresher
training to workers in their facilities to comply
with regulations and protect the health of
workers. Additionally, any organization involved
in the treatment, storage, and disposal of
hazardous waste must train employees according to
the HAZWOPER standards.
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