25

Common
Hazardous
Waste
Management 25 RCRA Compliance Mistakes
Easy-to-avoid Hazardous Waste Management Errors
Errors
This report lists 25 of the most common regulatory violations found at facilities that
generate and store hazardous waste.

Knowing how to spot these common errors will help you to keep facility personnel
safe, control your environmental impact, and avoid civil penalties that increase
every year. If you discover one of these common errors at your site, correct it
quickly—US EPA assesses civil penalties on a per day, per violation basis and those
penalties can add up fast.

By implementing a best management practice of self-audits and actively correcting

deficiencies, you can help protect your company’s reputation and bottom line.
In This Guide

Many commonly cited hazardous waste What’s Inside

management mistakes are easy to identify
and correct. This list will help you spot red
flags in your current waste management Hazardous Waste Training and Recordkeeping
operations to ensure successful, violation-
free inspections.
Containers, Tanks, and Storage Areas

Hazardous Waste Identification

Universal Waste

Managing Hazardous Waste in Laboratories

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 Hazardous Waste
Training and Recordkeeping
RCRA training and recordkeeping violations are among the most common
and easiest-to-spot incidents of noncompliance. When an inspector visits
your facility, training records and other documentation are often the first
items they will ask to see.

Learn more: RCRA Training FAQ.

Common RCRA Training and Common Error # 1

Recordkeeping Mistakes:
Failure to provide initial or annual refresher
RCRA training for personnel
1 Failure to provide initial or annual refresher RCRA training for personnel
Both large and small quantity generators must provide training for
“hazardous waste personnel.”
2 Incomplete facility training plans
Large quantity generators must provide training that satisfies the
3 Incomplete or non-existent RCRA training records requirements found in 40 CFR 262.17(a)(7). Annual refresher training is
required.

4 Employees signing the Hazardous Waste Manifest with no DOT hazmat training Small quantity generators must ensure that hazardous waste personnel are
“thoroughly familiar” with waste handling and emergency procedures so
that they can perform their jobs in a way that maintains compliance.
5 Inadequate contingency planning
Learn more: RCRA Training FAQ

6 No proof of container and tank inspections, or missing information

7 Failure to create or maintain a waste minimization plan

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 Containers, Tanks,
and Storage Areas
EPA’s RCRA regulations set specific requirements for how, where,
and how long facilities may manage and store containers and
tanks containing hazardous waste. Check your containers for these
commonly missed elements and make sure your site complies with
the rules for storage areas and accumulation time.

Common Container Management Mistakes:

Common Error # 8
8 Containers missing accumulation start dates

Containers missing accumulation start dates

9 Non-empty containers containing hazardous waste residues disposed of in regular trash
The RCRA regulations strictly limit the amount of time that hazardous waste
10 Satellite containers not closed or not properly closed may be stored in central accumulation areas. To make sure that waste is
moved or shipped off site before the clock runs out, generators must keep
track of when hazardous waste is first added to each container.
11 Satellite containers not marked with the words “Hazardous Waste” or other identifying words

12 Storing waste for longer than the 90 days, 180 days, or 270 days allowed

13 Failure to post emergency information at small quantity generator facilities

14 Incompatible wastes stored improperly

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 Hazardous Waste Identification
Identifying hazardous wastes and making accurate determinations is
a critical first step to compliance. But making the determination is not
enough. EPA requires thorough recordkeeping to “show your work.”
Accurate and timely records help to back up your compliance
decisions and create a paper trail that shows you made every effort to
comply with RCRA regulations.

Common Error # 15
Common Hazardous Waste ID Mistakes:
Failure to accurately determine generator status
15 Failure to accurately determine generator status
The exemptions that a facility may use to store hazardous waste depend
on the amount of waste generated each calendar month. Losing count
16 Failure to document use of RCRA exclusions of how much hazardous waste your facility generates can lead you to
overlook critical management standards, training mandates, or reporting
requirements that apply to your site.
Failure to document “generator knowledge” used to make a
17 hazardous waste determination
What’s My Generator Status?

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 Universal Waste
EPA allows generators to manage common industrial wastes like batteries,
lamps, pesticides, aerosol cans, and mercury-containing equipment under
a relaxed set of standards found at 40 CFR 273. That said, universal waste
management is not a free-for-all. To qualify for relief, universal wastes must
be managed according to specific standards.

Common RCRA Universal Waste Mistakes:

Common Error # 18
18 Lamp boxes not closed properly
Lamp boxes not closed properly
19 Universal waste labels with no indication of “type” of waste (e.g., “batteries” or “lamps”) Failure to store universal waste lamps (such as fluorescent lights) in a
closed container is an all-too-common violation related to universal waste.
Universal waste lamps must be stored in containers that are “structurally
20 Unacceptable abbreviations (e.g., “bat” for “batteries”)
sound,” and the containers/packages must remain closed (see 40 CFR
273.13 and 273.33).
21 Failure to mark or indicate the accumulation start date

22 Improper storage that does not prevent release to the environment

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 Managing Hazardous Waste
in Laboratories
Often, lab workers are surrounded by chemicals at work—on shelves,
in cabinets, under the sink, and elsewhere. Regardless of where they
are found, chemical containers must be kept in good condition.
If an inspector finds clearly abandoned chemicals in your lab, EPA will
consider the chemicals hazardous waste and expect that you manage
them in accordance with RCRA.

Common Mistakes in Labs

Common Error # 23
23 Unlabeled containers and “mystery brown bottles”
Unlabeled containers and “mystery brown bottles”
24 Degraded, broken, or dusty containers
Old, expired, or unused chemicals can accumulate on shelves and ultimately
become hazardous waste. While employees or students may know what’s in
25 Disposing of non-empty chemical containers in the regular trash each brown bottle around the lab, the RCRA regulations require hazardous
waste containers to be labeled and properly managed.

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 Get RCRA Training — When You Want, Where You Want
US EPA requires hazardous waste professionals to complete annual training on the RCRA
requirements. Lion makes it easy to meet your RCRA training mandate in a variety of formats—
nationwide public workshops, convenient online courses, live webinars, and on-site training.

RCRA Hazardous Waste Management

Learn how to properly identify, store, and dispose of regulated hazardous
wastes in compliance with RCRA regulations.

State Hazardous Waste Training

Many states enforce additional, more-stringent hazardous waste regulations for
generators. These online courses guide EH&S professionals through unique, state-
specific requirements.

California Texas New York Washington Massachusetts

ENROLL NOW

www.Lion.com 888-546-6511 [email protected]

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