![Hazardous Waste Graphic](https://www.heritagewastesolutions.com/wp-content/uploads/2022/04/Hazardous-Waste-drun.png)
With its ongoing importance, we want to update and inform on this old topic! Local, state and federal environmental agencies use the inspection process to verify that hazardous waste generators are following the rules. Over the last number of years, and with the implementation of the Generator Improvement Rules, we have a better understanding of what rules are consistently looked at, and can result in citations and fines if not followed. Below you will find rule violations and how to avoid them.
Failure to Make a Waste Determination
Avoid this by:
Knowing what you generate and if it is hazardous will help you make the determination as to what size generator you are, and what rules you need to follow…as well as ensuring that you aren’t improperly disposing of hazardous waste as non-hazardous and creating liability issues for your company.
Adequate Aisle Space
Avoid this by:
The regulations do not indicate a specific distance for adequate aisle space. Check state regulations for any state guidelines, or even fire marshal guidance.
Failure to Perform Weekly Inspections of Hazardous Waste Storage Areas
Avoid this by:
Make sure that your employees aren’t just documenting what issues they found, but also how the either mitigated them at that time, or if the issue was mitigated at a late time, how and when. Under the Generator Improvement Rules, remember that weekly inspections must now be completed “at least weekly” and must specifically look for containers that are leaking AND containers that have deteriorated due to corrosion.
Contingency Planning Violations
Avoid this by:
Do you know your capabilities? Do you know your local emergency responder’s capabilities for large release mitigation? Have you considered contracting with Heritage for your emergency response if you or your local responders aren’t able to mitigate large emergencies or decontamination’s?
Marking and Labeling of Containers
Either with “hazardous waste” OR Words describing the container contents
Avoid this by:
The GIR requires the words “Hazardous Waste” as well as an indication of the hazard (DOT diamond, GHS pictogram, etc.) in both satellite and central accumulation areas. Proper marking of containers will reduce the mixing of incompatible wastes, and potentially and emergency situation.
Separate incompatibles
Avoid this by:
The more you know about the wastes you have, the better prepared you are for reducing the risk of fires, releases or explosions.
Training
Avoid this by:
LQGs are required to have training annually, have a written training plan and that employees are training within 6 months of being hired to work in the company’s hazardous waste program. SQG employers need to show that the employees understand the rules based on their performance (i.e., do they know the rules and how they apply to the job).
Open Container Violations
Avoid this by:
Satellite and central accumulations area containers, as well as those for used oil, contaminated wipes, universal wastes, must be kept closed unless adding or removing material from the container. Are you ensuring that your containers are adequately closed?
Storage Area Accumulation Date Violations
Avoid this by:
90/180-day violations
Avoid this by:
This really captures all of the responsibilities you have as a generator in one major category. If you don’t do waste determinations, you don’t know what hazardous waste you generate and what size generator you are. From there, you may not know how long you are allowed to store hazardous waste on site, and when it needs to be transported for disposal. This could lead to storage violations, and a host of other violations based on how the rules apply to you, and if you follow them.
Learn more about our Hazardous Waste Services.
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