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Preparing for Rgulatory Hazardous Waste Program Inspection

By Greg Rosinski, Chemist II

Preparedness for a regulatory inspection can help to ease the stress in advance. Environmental Health and Safety Personnel involved in a Hazardous Waste Program should keep track of the follow items on regularly. The follow list is not the end all of lists, but it encompasses the major items an inspector will look for.

o The last three years of:

     o Manifests

     o Land Disposal Record’s (LDRs)

     o Profiles for waste streams

     o Main Accumulation Area inspections

o Make sure the site you are working at maintains up to date RCRA/OSHA/DOT records of each employee on site that works with Hazardous material.

o Generator needs to have the original EPA ID application, and the verification letter from the EPA

o Maintain complete compliance of Main Accumulation Areas (MAA) and Satellite Accumulation Areas (SAA).

o Keep any records of MAA or SAA compliance issues along with corrective actions taken.

o Spill Prevention, Control and Countermeasure Plan (SPCC Plan)

o Hazardous Communication Plan (HAZCOM) Plan

o Material and Safety Data Sheets (MSDS) of chemicals onsite

o In addition to the Waste profiles it is important to keep MSDS and any analytical along with a Non Hazardous Profile. This helps to support why the Non- Hazardous profile was chosen over a Hazardous Waste Profile.

o Compliance of Satellite Accumulation Areas with monthly Inspection Reports

o Check your states regulations regarding the management of recycled chemicals. This includes the labeling in an accumulation area.

In the event of an unplanned inspection from a regulatory agency should happen. Contacting specially trained compliance advisers within Triumvirate Environmental, Inc., gives a company the ability to have a pre-audit to review the compliance onsite before a regulatory agency comes onsite. Triumvirate Environmental, Inc. also can staff personnel that will come on site regularly to ensure continued compliance on site of Hazardous Waste Management.