How Often to Inspect Hazardous Waste Containers

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How Often You Need to Inspect Hazardous Waste Containers
by Karen

If your facility creates or handles hazardous waste, it can be stored onsite without a permit for 90, 180 or 270 days — depending on your waste generator status and the distance that the waste will be hauled for treatment, recycling or disposal. While that waste is onsite, the Environmental Protection Agency (EPA) requires weekly inspections. Inspection records also must be kept to verify compliance.

Note: inspections aren’t required for Very Small Quantity Generators (VSQGs).

The purpose of weekly inspections is to make sure that each container is in good condition (free from rust, dents, cracks or any other signs of corrosion). If it is discovered early enough, contents of a container that is rusted or otherwise compromised can be transferred to another container before a leak or spill happens.

Weekly inspections are also beneficial in other ways. Inspections verify that wastes are being stored safely to prevent harm to employees or the environment. For example, a weekly inspection might uncover incompatible materials that are stored too close to each other or ignitable wastes too close to the property line. The earlier harmful situations are found, the earlier they can be corrected before an incident happens.

Compliance with container labeling requirements and storage time limits can also be verified during weekly inspections. Hazardous waste containers need to be clearly marked with the words “hazardous waste,” a description of the contents and an accumulation start date. The accumulation start date can be used to confirm that hazardous waste containers are moved offsite within the required 90, 180 or 270 days.

You tell us: How often do you inspect your hazardous waste containers? More than the weekly requirement by the EPA? Let us know in the comments section below!

TAGS: Hazardous Waste

Karen

Karen D. Hamel CSP, CET, WACH, is a regulatory compliance professional, trainer and technical writer. She has more than 25 years of experience helping EHS professionals find solutions to meet EPA, OSHA and DOT regulations and has had more than 200 articles published on a variety of EHS topics. Karen is a Certified Safety Professional (CSP), Certified Environmental health and Safety Trainer (CET), Walkway Auditor Certificate Holder (WACH), OSHA-Authorized Outreach Trainer for General Industry, Community Emergency Response Team (CERT) trainer and hazmat technician. She serves on the Blair County, PA LEPC. Her specialties include a wide variety of environmental, safety, emergency response, risk management, DOT and NIMS topics. She conducts trainings and seminars at national conferences and webinars for several national organizations. For regulation or product information, we can be reached at 1-800-HOT-HOGS (468-4647) or by email at xtechnical@newpig.com.

3 Comments

Robsays:
03/21/2016 at 8:35 pm Reply
Karen,

You state….”Hazardous waste containers need to be clearly marked with the words “hazardous waste,” a description of the contents and an accumulation start date. The accumulation start date can be used to confirm that hazardous waste containers are moved offsite within the required 90, 180 or 270 days.” I have been looking at switching waste disposal companies and they both have a different take on “accumulation” start date. I have always understood this to mean the first day waste is added to that waste stream then once that container becomes full then it moves to storage. I fall under SQG but could most likely apply for conditionally exempt. When does the 180 start and how does that apply to storage. The more I listen, the more I start to question what I think I know.
- Karensays:
  03/22/2016 at 1:18 pm Reply
  Hi Rob,
  
  Thank you for your comment. RCRA’s rules for hazardous waste generators can be confusing – and even seem to contradict themselves at times.
  
  As a small quantity generator, your rules for accumulation time without a permit are in 40 CFR 262.34(d). You are correct on the 180 day time limit for storage without a permit (unless your waste will be transported more than 200 miles, then you get some additional time). You are also required to meet the requirements of:
  - 40 CFR 265, Subpart I (except .176 and .178): use and management of containers- make sure the contents are compatible and the container is kept closed when waste is not being added or removed
  - 40 CFR 265.201: this is specific to waste stored in tanks
  - 40 CFR 262.34(a)(2): the container must be marked with an accumulation start date
  - 40 CFR 262.34(a)(3): the container must be marked with the words “hazardous waste”
  - 40 CFR 268: Land disposal restrictions
  There are some states that vary on accumulation start date rules, which can add to confusion. You should check your state’s environmental site for state-specific rules that supersede and can be more stringent than the federal rule.
  
  Under the federal rule, the accumulation start date is the date when the first drop of waste is added to a container of hazardous waste in a central waste storage area. If you are accumulating wastes in satellite storage areas then moving them to a central waste storage area when the amount of waste exceeds 55 gallons (or one quart of acute hazardous waste), the accumulation start date is the date that the container arrives in the central waste storage area. If you are not utilizing satellite accumulation areas and instead collect wastes from different areas in a centralized waste collection area, the accumulation start date is the date that the waste is first added to a collection container.
  
  Hope this information helps! Please leave another comment if you have any further questions.
  
  Thanks,
  Karen
Britney Perrysays:
12/17/2020 at 9:25 am Reply
Thanks for this information

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