MOST COMMON HAZARDOUS WASTE CONTAINER VIOLATIONS AND HOW TO AVOID THEM
If you are a generator of hazardous waste, the first stop an inspector will likely make when conducting an inspection at your facility is the hazardous waste accumulation or storage area. This might be because there are a few common mistakes generators tend to make in connection with their hazardous waste containers.
Here are a few of the most common container violations you should be aware of:
- Not keeping containers closed. Inspectors often observe hazardous waste drums that have been left open during the entire work shift, or drums with open funnels.
- No accumulation start date is marked on the container. If you are a generator accumulating hazardous waste on-site without a permit, you must be sure to clearly mark on each container the date which each period of accumulation begins.
- Failure to document inspections. Generators as well as TSDF owners and operators are required to inspect, at least weekly, areas where containers are stored. These facilities often cannot produce documentation that such inspections have occurred. Inspectors may ask to review up to 3 years of inspection records.
- Containers missing the words “Hazardous Waste” or other required information on the container. Keep in mind that some states also require additional information on the container, such as the hazardous waste number or chemical name that identifies the container’s contents.
- Using improper containers or containers are in poor condition. Your containers must be in good condition and lined with material that will not react with the hazardous waste being stored therein.
- Failing to comply with the special satellite accumulation area rules. Generators accumulating hazardous waste on-site without a permit in accordance with the accumulation rules may accumulate up to 55 gallons (gal) of hazardous waste or 1 quart of acutely hazardous waste in their satellite accumulation area, provided specific requirements are met. Violations include an absence of operator control of the process generating the waste, failure to list the date the satellite container reaches its accumulation limit (55 gal for hazardous waste or 1 quart of acutely hazardous waste), and failure to remove the waste from the satellite area within 3 days of exceeding the quantity limitations.
Getting hit with one of these violations will most likely earn you the dubious honor of being known as a facility that will need to be carefully examined by your state environmental agency inspectors in future visits. Also, a history of noncompliance can affect the severity of future penalties. You can keep your wallets and reputations intact by carefully following the container management rules.