Hazardous
Waste
Self-Inspection Checklist |
Guidelines: This checklists covers regulations issued
by the United States Environmental Protection Agency (EPA) regarding the
generation, management, and disposal of hazardous wastes. Most states enforce
these regulations as well as some of their own.
It is
important to know that you may not be covered by federal or state regulations.
Only specific waste materials, generated at one facility in specific
quantities, are regulated. Lists of regulated materials, found in 40 CFR
261.31, 261.32, and 261.33, are available from your state environmental agency.
Contact them for complete information for your facility.
If,
after reviewing the listed sources identified above, you are unable to identify
your waste, you must then determine if your waste may still be classified as
hazardous waste by the Hazardous Waste Identification Questionnaire below. If
you determine that you have hazardous waste, you must then determine if, as a
facility, you have a regulated quantity of waste. If in a calendar month you
generate or accumulate more than 100 kg (220 lb) of a hazardous waste or more
than 1 kg (2.2 lb) of an acutely hazardous waste, you are a regulated generator
and must obtain an EPA ID number (Form 8700-12) from the EPA.
Hazardous Waste Identification Questionnaire
Is the waste ignitable?
§ The
waste must be a liquid with a flash point below 140ºF.
§ The
waste is capable of causing fire through friction, absorption, moisture or
spontaneous chemical changes.
§ The
waste is an ignitable compressed gas.
§ The
waste is classified as an oxidizer by the United States Department of
Transportation.
Is the waste corrosive?
§ The
waste must be a liquid with a pH less than or equal to 2 or has a pH greater
than or equal to 12.6.
Is the waste reactive?
§ The
waste is unstable and readily undergoes violent reaction without detonation.
§ The
waste reacts violently with water.
§ The
waste, when mixed with water, forms potentially explosive mixtures.
§ The
waste, when mixed with water, forms toxic gases or fumes.
§ The
waste contains cyanide or sulfides which generate toxic gases when exposed to a
pH less than or equal to 2 or greater than or equal to 12.5.
Is the waste toxic?
Does
the waste contain leachable levels of certain metals or chemical contaminants?
This is typically determined by performing a Toxicity Characteristic Leaching
Procedure or TCLP test.
WASTE HANDLING PROCEDURES
While
waste is being held for disposal, it must be managed in accordance with state
and federal regulations. It is strongly recommended that you set
up a disposal procedure that takes advantage of satellite rules, since
regulations governing satellite accumulations are much less burdensome.
Satellite rules apply to "active drums" that are used to accumulate
hazardous waste. Satellite rules can be followed as long as filled drums are
transferred to an authorized accumulation area within three days. A second drum
can be utilized as a satellite drum until the original drum is moved to an
authorized storage area. This checklist does not address hazardous waste stored
in tanks and treatment, storage and disposal (TSD) facilities.
Questions
marked with this symbol may require the help of an outside expert.
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Please
Circle
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Generators of Regulated Amounts of Hazardous Waste
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1. Does
the container storing hazardous waste meet US Department of
Transportation container requirements? [40
CFR 262.30]
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Y N N/A
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2. Is
the container storing hazardous waste in good condition? [40
CFR 265.171]
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Y N N/A
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3. Is
the container storing hazardous waste compatible with
the waste material? (For instance, solvents and paint
waste should be placed in steel drums, but
acidic or alkaline waste should not be placed in steel drums.) [40 CFR 265.172] |
Y N N/A
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4. Is
the container storing hazardous waste kept securely closed when not in use?
[40 CFR 265.173a] |
Y N N/A
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5. Is
the container storing hazardous waste at or near the point
of generation and under the operator's control? [40
CFR 262.34(c)(1)]
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Y N N/A
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6. Is
the container storing hazardous waste marked with the
words "Hazardous Waste"? [40
CFR 262.34(a)(3)]
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Y N N/A
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7. If
the container is being shipped for disposal, have arrangements
been made for a Licensed Treatment, Storage,
and Disposal (TSD) facility to accept your
hazardous wastes? [40 CFR 265.20]
Note: Although the employer is responsible for
completing manifest forms, the TSD facility handling your waste should
be consulted about completing the paperwork necessary
to ship hazardous waste. [40 CFR 262.20]
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Y N N/A
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If the container is being shipped for disposal, have arrangements
with a registered Hazardous Waste Hauler been
made for transport of wastes to the TSD facility? [40
CFR 262.20]
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Y N N/A
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9. Have
Hazardous waste manifests been completed for all
shipments of hazardous wastes within your state (or other
State's Manifest for shipments to other States)? [40
CFR 262.20]
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Y N N/A
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10. Has a
copy of the manifest with the signature of the initial transporter
and date of shipment been retained by the employer? [40
CFR 262.23(a)]
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Y N N/A
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11. Has
the Hauler been supplied with all remaining copies of
the manifest?
[40 CFR 262.23(b)] |
Y N N/A
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12. Have
Land Ban forms been completed prohibiting land disposal
of affected wastes unless treated below regulatory
levels? [40 CFR 268.7]
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Y N N/A
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13. Have
appropriate markings and labels been affixed to
containers prior to shipment? [40 CFR 262.31 and 262.32]
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Y N N/A
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14. Has
the Hauler's vehicle been inspected by the generator (or
his/her designee) to ensure proper placarding before leaving
the generators premises?
[40 CFR 262.33] |
Y N N/A
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15. Has
the employer kept a copy of each signed manifest for
at least three years, or until a copy if received from the owner and operator
of the facility which received the waste for at least three years? [40
CFR 262.40(a)]
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Y N N/A
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16. Has
the employer prepared and submitted a copy of a
Biennial Report to the EPA Regional Administrator by
March 1 of each even numbered year for all hazardous waste
shipped off-site for treatment, storage or disposal?
[40 CFR 262.41] |
Y N N/A
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Satellite Accumulation Sites
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17. Is
the quantity of waste less than 55 gallons or less than 1
quart for acutely toxic waste? [40 CFR 262.34(c)(1)]
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Y N N/A
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18. If
the quantities of hazardous waste exceed the amounts in
question 17, are the containers moved within three days
to a less than 90-day accumulation area or off site to an
authorized facility? [40 CFR 262.34(c)(1)]
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Y N N/A
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Small Quantity Generator (Generate between 100 and 1000 Kilograms of Hazardous Waste Per
Month
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19. Have
hazardous waste containers been accumulated at
your facility for 180 days or less? [40
CFR 262.34(f)]
Note: If you store hazardous waste for more
than 180 days, additional regulations apply which are not
covered in this checklist. Contact your state
environmental agency for additional information. The quantity of waste accumulated on-site may never exceed 6000 kilograms. Wastes may be stored longer than 180 days for certain situations. |
Y N N/A
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20. Are
containers marked with accumulation start date? [40
CFR 262.34(a)(2)]
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Y N N/A
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21. Are
container labels visible? [40 CFR 262.34(a)(2)]
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Y N N/A
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22. Are
containers segregated according to waste type? [40
CFR 265.177]
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Y N N/A
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23. Are
the containers inspected weekly? [40
CFR 265.174]
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Y N N/A
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24. Is
there adequate aisle space between container rows?
Note: 18 inches between single stacked drums and
30 inches between double or triple stacked drums [40
CFR 265.35]
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Y N N/A
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25. Is
there immediate access to communication or alarm systems
whenever hazardous waste is poured, mixed
or handled? [40 CFR 265.32 and 265.34(a)(b)]
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Y N N/A
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26. Is
there an adequate supply of fire extinguishers and
spill control equipment in the accumulation area? [40
CFR 265.32(c)]
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Y N N/A
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27. Is
there adequate water pressure to supply fire hoses?
[40 CFR 265.32(d)] |
Y N N/A
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28. Is
the fire fighting equipment, communications and
alarm equipment, and decontamination equipment, spill
control and water supply tested and maintained? [40
CFR 265.33]
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Y N N/A
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29. Have
the police, fire department and emergency response
teams been familiarized with the layout of
the facility? [40 CFR 265.37(a)(1)]
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Y N N/A
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30. Are
there written agreements with emergency response
contractors and equipment suppliers? [40
CFR 265.37(a)(2)and(3)]
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Y N N/A
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31. Have arrangements
been made with the local hospitals to familiarize them with the properties of
the hazardous waste handled at your facility and
the types of injuries which may result from contact
with these wastes? (This is usually a
letter to the local hospitals identifying the wastes generated and the types of injuries that result from contact with the waste.) [40 CFR 265.37(a)(4)] |
Y N N/A
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32. Is
there an emergency coordinator on-site or on call
who is available to respond to an emergency? [40
CFR 262.34(d)(5)(i)]
Note: The emergency coordinator or his
designee must respond to any emergencies that arise.
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Y N N/A
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33. Is
the following information posted next to the
telephone: the name and telephone number
of the emergency coordinator; the location
of fire extinguishers and spill control material,
and, if present, fire alarm; and the
telephone number of the fire department, unless the facility has a direct alarm? [40 CFR 262.34(d)(5)(ii)]
Note: In the event of a fire, explosion or
other release which could threaten human health outside
the facility or when the generator has knowledge
that a spill has reached surface water, the generator must immediately
notify the National Response
Center (using their
24-hour toll free number 800-424-8802.
[40 CFR 262.34(d)(5)(iv)(c)] |
Y N N/A
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34. Are
all employees thoroughly familiar with proper waste
handling and emergency procedures, relevant
to their responsibilities during normal facility
operations and emergencies? [40 CFR 262.34(d)(5)(iii)] |
Y N N/A
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35. Has
the school notified the EPA Regional Administrator
of any manifests which were not received
for shipments made to a designated facility
within 60 days?
[40 CFR 262.42(b)] |
Y N N/A
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Large Quantity Generator (Generate More Than 1000 Kilograms of Hazardous Waste Per
Month
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36. Have
hazardous waste containers been accumulated at
your facility for 90 days or less? [40
CFR 262.34(g)]
Note: If you store hazardous waste for more than
90 days, additional regulations apply which are
not covered in this checklist. Contact your state
environmental agency for additional information. |
Y N N/A
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37. Are
containers marked with accumulation start date? [40
CFR 262.34(q)(4)(iii)]
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Y N N/A
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38. Are
container labels visible? [40 CFR 262.34(q)]
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Y N N/A
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39. Are
containers segregated according to waste type?
[40 CFR 265.177)(a)and(c)] |
Y N N/A
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40. Are
the containers inspected weekly? [40
CFR 265.174]
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Y N N/A
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41. Are
containers of ignitable and reactive wastes located greater
than 50 feet from the facility's property line? [40
CFR 265.176]
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Y N N/A
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42. Is
there adequate aisle space between container rows? [40
CFR 265.35]
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Y N N/A
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43. Is
there immediate access to communication or alarm
systems whenever hazardous waste is poured,
mixed or handled? [40 CFR 265.32 and 265.34(a)(1)]
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Y N N/A ??
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44. Is
there an adequate supply of fire extinguishers and
spill control equipment in the accumulation area? [40
CFR 265.32(c)]
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Y N N/A
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45. Is
there adequate water pressure to supply fire hoses? [40
CFR 265.32(a)(1)]
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Y N N/A
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46. Is
the fire fighting equipment, spill control and water supply
tested and maintained? [40 CFR 265.33(a)(2)and(3)]
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Y N N/A
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47. Have
the police, fire department and emergency response
teams been familiarized with the layout
of the facility? [40 CFR 265.37(a)(1)]
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Y N N/A
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48. Are
there written agreements with emergency response
contractors and equipment suppliers? [40
CFR 265.37(a)(2)and(3)]
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Y N N/A
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49. Have
arrangements been made with the local hospitals
to familiarize them with the properties of
the hazardous waste handled at your facility and
the types of injuries which may result from contact
with these wastes? (This is usually a
letter to the local hospitals identifying the wastes generated and the types of injuries that result from contact with the waste.) [40 CFR 265.37(a)(4)] |
Y N N/A
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50. Has a
contingency plan been developed describing
the actions to be taken by facility personnel
in the event of a fire, explosion or hazardous
materials release? [40 CFR 265.51]
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Y N N/A
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51. Does
the plan describe arrangements with local
authorities including fire police, and emergency
medical services personnel, for handling
such emergencies?
[40 CFR 265.52(c)] |
Y N N/A
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52. Does
the plan list telephone numbers for the emergency
coordinator and alternates? [40 CFR 265.52(c)]
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Y N N/A
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53. Does
the plan list the locations and capabilities of
emergency equipment kept at the facility including fire extinguishers, spill
control equipment and communications and alarm systems
and decontamination systems?
[40 CFR 265.52(e)] |
Y N N/A
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54. Does
the plan include primary and alternate evacuation
routes for employees?
[40 CFR 265.52(f)] |
Y N N/A
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55. Is a
copy of the plan available at the facility for inspection?
[40 CFR 265.53(a)] |
Y N N/A
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56. Has a
copy of the plan been forwarded to local
emergency agencies including police, fire,
emergency medical, the local emergency planning
committee, and any emergency response contractors who may
be called upon during an incident? [40
CFR 265.53(b)]
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Y N N/A
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57. Are
there provisions for updating the Contingency Plan
as operations and/or personnel change? [40
CFR 265.54]
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Y N N/A
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58. Is
the training program directed by a person trained
in hazardous waste management procedures? [40
CFR 264.16(a)(2)]
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Y N N/A
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59. Is
the training program designed to ensure that personnel
are able to respond effectively? [40
CFR 264.16(a)(3)]
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Y N N/A
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60. Does
the training program include:
[40 CFR 264.16(a)(3) (i) Procedures for using, inspecting, repairing, and replacing facility emergency and monitoring equipment; (ii) Key parameters for automatic waste feed cut-off systems; (iii) Communications or alarm systems; (iv) Response to fires or explosions; (v) Response to ground-water contamination incidents; and (vi) Shutdown of operations.]
a. The
use of personnel safety equipment?
b. Procedures
for using facility emergency and monitoring
equipment?
c. Procedures
for utilizing communications or alarm systems?
d. Response
procedures for fires and explosions?
e. Ground
water contamination response procedures?
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Y N N/A
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61. Is
training provided within 6 months of the date of
employment or assignment to an area involving
the handling of hazardous waste? [40
CFR 264.16(b)]
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Y N N/A
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62. Is
training reviewed annually? [40 CFR 264.16(c)]
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Y N N/A
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63. Is training
documented with the following information: 1) Job title for
each position and the name of the person filling each job; 2) A
written job description; 3) A description of
the training given; and 4) Documentation
of actual training? [40 CFR 264.16(d)] |
Y N N/A
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64. Are
training records maintained for at least three
(3) years? [40 CFR 264.16(e)]
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Y N N/A
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65. Has
the employer contacted the transporter and/or owner
or operator of the designated facility of any
manifests which were not received for shipments
made to a designated facility within 35 days? [40
CFR 262.42(a)(2)]
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Y N N/A
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66. Has
an Exception Report been submitted to the EPA
regional Administrator if the generator has not
received a copy of the manifest within 45 days?
[40 CFR 262.42(a)(2)]
Note: Efforts to obtain the manifest must be documented.
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Y N N/A
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67. Are
Biennial Reports and Exception reports kept on
file for 3 years?
[40 CFR 262.40(b)] |
Y N N/A
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