Creating and maintaining great procedures is important for hazardous waste small quantity generators to effectively manage their waste streams and minimize the risk of state and federal fines. One of the most crucial practices that your company can do is establish, perform and document weekly inspections of hazardous waste storage areas. A regular and through inspection will quickly reveal small problems that are easy to fix and prevent them from turning into large problems that are time consuming and potentially costly to repair.
If hazardous waste is accumulated in containers, a generator must comply with Title 22, Cal. Code Regs., division 4.5, chapter 15, article 9 (Use and Management of Containers).
Inspections should be done once a week ideally on the same day. Being consistent and following through are critical, so you should evaluate your workflow and pick one day of the week that this can be accomplished. Once you pick your inspection day you will need to have both a designated inspector and a back-up inspector to ensure that you will never miss a week. Both of these employees must be trained on proper procedures and must fill out an inspection checklist documenting that these inspections have been completed.
Record your weekly inspections in an inspection log.
The Environmental Protection Agency (EPA) provides guidance and weekly inspections should consist of the following at a minimum:
By making sure to check each of these things every week you will ensure that your company is not responsible for any hazardous waste accidents and ensures that you will not get in trouble with the EPA or California Department of Toxic Substances Control (DTSC). For more great information on handling your hazardous waste, subscribe to our blog, or download a copy of our free eBook “Handling Hazardous Waste.”