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.Please Circle | ||
Generators of Regulated Amounts of Hazardous Waste | ||
| 1. Does the container storing hazardous waste meet US Department of Transportation container requirements?[40 CFR 262.30] | Y N N/A |
2. Is the container storing hazardous waste in goodcondition?[40 CFR 265.171] | Y N N/A | |
3. Is the container storing hazardous waste compatiblewith the waste material? (For instance, solvents andpaint waste should be placed in steel drums, but acidic or alkaline waste should not be placedin steel drums.)[40 CFR 265.172] | Y N N/A | |
4. Is the container storing hazardous waste kept securely closed when not in use? [40 CFR 265.173a] | Y N N/A | |
5. Is the container storing hazardous waste at or near thepoint of generation and under the operator's control?[40 CFR 262.34(c)(1)] | Y N N/A | |
6. Is the container storing hazardous waste marked withthe words "Hazardous Waste"?[40 CFR 262.34(a)(3)] | Y N N/A | |
7. If the container is being shipped for disposal, havearrangements 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 completingmanifest forms, the TSD facility handling your wasteshould be consulted about completing the paperworknecessary to ship hazardous waste.[40 CFR 262.20] | Y N N/A | |
If the container is being shipped for disposal, havearrangements with a registered Hazardous Waste Haulerbeen made for transport of wastes to the TSD facility?[40 CFR 262.20] | Y N N/A | |
| 9. Have Hazardous waste manifests been completed forall shipments of hazardous wastes within your state (orother State's Manifest for shipments to other States)?[40 CFR 262.20] | Y N N/A |
10. Has a copy of the manifest with the signature of the initialtransporter and date of shipment been retained by the employer?[40 CFR 262.23(a)] | Y N N/A | |
11. Has the Hauler been supplied with all remaining copiesof the manifest? [40 CFR 262.23(b)] | Y N N/A | |
| 12. Have Land Ban forms been completed prohibiting landdisposal of affected wastes unless treated belowregulatory levels?[40 CFR 268.7] | Y N N/A |
| 13. Have appropriate markings and labels been affixedto containers prior to shipment?[40 CFR 262.31 and 262.32] | Y N N/A |
14. Has the Hauler's vehicle been inspected by the generator(or his/her designee) to ensure proper placarding beforeleaving the generators premises? [40 CFR 262.33] | Y N N/A | |
15. Has the employer kept a copy of each signed manifestfor 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)] | Y N N/A | |
16. Has the employer prepared and submitted a copy ofa Biennial Report to the EPA Regional Administratorby March 1 of each even numbered year for all hazardouswaste shipped off-site for treatment, storage or disposal? [40 CFR 262.41] | Y N N/A | |
Satellite Accumulation Sites | ||
17. Is the quantity of waste less than 55 gallons or less than1 quart for acutely toxic waste?[40 CFR 262.34(c)(1)] | Y N N/A | |
18. If the quantities of hazardous waste exceed the amountsin question 17, are the containers moved within threedays to a less than 90-day accumulation area or off siteto an authorized facility?[40 CFR 262.34(c)(1)] | Y N N/A | |
Small Quantity Generator (Generate between 100 and1000 Kilograms of Hazardous Waste Per Month | ||
19. Have hazardous waste containers been accumulatedat your facility for 180 days or less?[40 CFR 262.34(f)] Note: If you store hazardous waste for more than180 days, additional regulations apply which arenot covered in this checklist. Contact your state environmental agency for additional information.The quantity of waste accumulated on-site maynever exceed 6000 kilograms. Wastes may be stored longer than 180 days for certain situations. | Y N N/A | |
20. Are containers marked with accumulation start date?[40 CFR 262.34(a)(2)] | Y N N/A | |
21. Are container labels visible?[40 CFR 262.34(a)(2)] | Y N N/A | |
22. Are containers segregated according to waste type?[40 CFR 265.177] | Y N N/A | |
23. Are the containers inspected weekly?[40 CFR 265.174] | Y N N/A | |
24. Is there adequate aisle space between containerrows? Note: 18 inches between single stacked drumsand 30 inches between double or triple stacked drums[40 CFR 265.35] | Y N N/A | |
25. Is there immediate access to communication or alarmsystems whenever hazardous waste is poured,mixed or handled?[40 CFR 265.32 and 265.34(a)(b)] | Y N N/A | |
26. Is there an adequate supply of fire extinguishersand spill control equipment in the accumulation area?[40 CFR 265.32(c)] | Y N N/A | |
| 27. Is there adequate water pressure to supply fire hoses? [40 CFR 265.32(d)] | Y N N/A |
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] | Y N N/A | |
29. Have the police, fire department and emergencyresponse teams been familiarized with the layoutof the facility?[40 CFR 265.37(a)(1)] | Y N N/A | |
30. Are there written agreements with emergencyresponse contractors and equipment suppliers?[40 CFR 265.37(a)(2)and(3)] | Y N N/A | |
31. Have arrangements been made with the localhospitals to familiarize them with the propertiesof the hazardous waste handled at your facilityand the types of injuries which may result fromcontact with these wastes? (This is usually a letter to the local hospitals identifying the wastesgenerated and the types of injuries that resultfrom contact with the waste.)[40 CFR 265.37(a)(4)] | Y N N/A | |
32. Is there an emergency coordinator on-site or oncall who is available to respond to an emergency?[40 CFR 262.34(d)(5)(i)] Note: The emergency coordinator or his designeemust respond to any emergencies that arise. | Y N N/A | |
33. Is the following information posted next tothe telephone: the name and telephonenumber of the emergency coordinator; thelocation of fire extinguishers and spill controlmaterial, 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 NationalResponse Center (using their 24-hour toll freenumber 800-424-8802. [40 CFR 262.34(d)(5)(iv)(c)] | Y N N/A | |
34. Are all employees thoroughly familiar with properwaste 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 | |
35. Has the school notified the EPA RegionalAdministrator of any manifests which were notreceived for shipments made to a designatedfacility within 60 days? [40 CFR 262.42(b)] | Y N N/A | |
Large Quantity Generator (Generate More Than1000 Kilograms of Hazardous Waste Per Month | ||
36. Have hazardous waste containers been accumulatedat your facility for 90 days or less?[40 CFR 262.34(g)] Note: If you store hazardous waste for morethan 90 days, additional regulations apply whichare not covered in this checklist. Contact your state environmental agency for additional information. | Y N N/A | |
37. Are containers marked with accumulation start date?[40 CFR 262.34(q)(4)(iii)] | Y N N/A | |
38. Are container labels visible?[40 CFR 262.34(q)] | Y N N/A | |
39. Are containers segregated according to waste type? [40 CFR 265.177)(a)and(c)] | Y N N/A | |
40. Are the containers inspected weekly?[40 CFR 265.174] | Y N N/A | |
41. Are containers of ignitable and reactive wastes locatedgreater than 50 feet from the facility's property line?[40 CFR 265.176] | Y N N/A | |
42. Is there adequate aisle space between containerrows?[40 CFR 265.35] | Y N N/A | |
43. Is there immediate access to communication oralarm systems whenever hazardous waste ispoured, mixed or handled?[40 CFR 265.32 and 265.34(a)(1)] | Y N N/A ?? | |
44. Is there an adequate supply of fire extinguishersand spill control equipment in the accumulation area?[40 CFR 265.32(c)] | Y N N/A | |
| 45. Is there adequate water pressure to supply fire hoses?[40 CFR 265.32(a)(1)] | Y N N/A |
46. Is the fire fighting equipment, spill control and watersupply tested and maintained?[40 CFR 265.33(a)(2)and(3)] | Y N N/A | |
47. Have the police, fire department and emergencyresponse teams been familiarized with thelayout of the facility?[40 CFR 265.37(a)(1)] | Y N N/A | |
48. Are there written agreements with emergencyresponse contractors and equipment suppliers?[40 CFR 265.37(a)(2)and(3)] | Y N N/A | |
49. Have arrangements been made with the localhospitals to familiarize them with the propertiesof the hazardous waste handled at your facilityand the types of injuries which may result fromcontact with these wastes? (This is usually a letter to the local hospitals identifying the wastesgenerated and the types of injuries that resultfrom contact with the waste.)[40 CFR 265.37(a)(4)] | Y N N/A | |
50. Has a contingency plan been developeddescribing the actions to be taken by facilitypersonnel in the event of a fire, explosion orhazardous materials release?[40 CFR 265.51] | Y N N/A | |
51. Does the plan describe arrangements withlocal authorities including fire police, andemergency medical services personnel, forhandling such emergencies? [40 CFR 265.52(c)] | Y N N/A | |
52. Does the plan list telephone numbers for theemergency coordinator and alternates?[40 CFR 265.52(c)] | Y N N/A | |
53. Does the plan list the locations and capabilitiesof emergency equipment kept at the facility including fire extinguishers, spill controlequipment and communications and alarmsystems and decontamination systems? [40 CFR 265.52(e)] | Y N N/A | |
54. Does the plan include primary and alternateevacuation routes for employees? [40 CFR 265.52(f)] | Y N N/A | |
55. Is a copy of the plan available at the facility forinspection? [40 CFR 265.53(a)] | Y N N/A | |
56. Has a copy of the plan been forwarded tolocal emergency agencies including police,fire, emergency medical, the local emergencyplanning committee, and any emergencyresponse contractors who may be called uponduring an incident?[40 CFR 265.53(b)] | Y N N/A | |
57. Are there provisions for updating the ContingencyPlan as operations and/or personnel change?[40 CFR 265.54] | Y N N/A | |
58. Is the training program directed by a persontrained in hazardous waste management procedures?[40 CFR 264.16(a)(2)] | Y N N/A | |
59. Is the training program designed to ensure thatpersonnel are able to respond effectively?[40 CFR 264.16(a)(3)] | Y N N/A | |
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 andmonitoring equipment? c. Procedures for utilizing communicationsor alarm systems? d. Response procedures for fires and explosions? e. Ground water contamination responseprocedures? | Y N N/A | |
61. Is training provided within 6 months of the dateof employment or assignment to an areainvolving the handling of hazardous waste?[40 CFR 264.16(b)] | Y N N/A | |
62. Is training reviewed annually?[40 CFR 264.16(c)] | Y N N/A | |
63. Is training documented with the followinginformation: 1) Job title for each position andthe name of the person filling each job;2) A written job description; 3) A descriptionof the training given; and 4) Documentation of actual training?[40 CFR 264.16(d)] | Y N N/A | |
64. Are training records maintained for at leastthree (3) years?[40 CFR 264.16(e)] | Y N N/A | |
65. Has the employer contacted the transporter and/orowner or operator of the designated facility ofany manifests which were not received forshipments made to a designated facility within 35 days?[40 CFR 262.42(a)(2)] | Y N N/A | |
66. Has an Exception Report been submitted to theEPA regional Administrator if the generator hasnot received a copy of the manifest within 45 days? [40 CFR 262.42(a)(2)] Note: Efforts to obtain the manifest must bedocumented. | Y N N/A | |
67. Are Biennial Reports and Exception reports kepton file for 3 years? [40 CFR 262.40(b)] | Y N N/A | |
