Here’s a quick overview of basic RCRA recordkeeping requirements for hazardous waste generators.
The importance of proper recordkeeping for compliance with the Resource Conservation and Recovery Act (RCRA) is best illustrated by the fact that many of the most common hazardous waste generator violations issued involve a lack of proper recordkeeping.
The regulations require several different kinds of records be kept concerning hazardous waste (check 40 CFR Supart D for specifics). Here’s a list of major records specified by EPA in the RCRA regulations as well as additional records considered prudent to maintain, though there is no specific requirement to do so:
- Hazardous waste identification and change in notification forms
- Hazardous waste determinations
- Container accumulation area inspection logs
- Training records for current employees
- Training records for former employees
- Manifests
- Bills of lading
- Exception reports
- Reclamation agreements
- International shipment records
- Biennial Reports
- Land disposal restrictions
Many states have recordkeeping requirements that are in addition to or stricter than the federal.
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Records and Inspections
Often, both federal and state hazardous waste inspectors look first at a facility’s hazardous waste management records during an inspection. Inspectors will examine the files, noting how they are organized and maintained and attention or lack of attention to detail.
Looking at the records of the facility often gives inspectors an indication that problems with the hazardous waste management system exist. From the inspector’s point of view sloppy recordkeeping could easily go hand in hand with problems in other parts of the operation.
This makes keeping records that are logically organized, carefully completed, and up-to-date critical. The first impression left with an inspector is usually very important. If the first impression is negative, it can be almost impossible to overcome. Inspectors who get a negative first impression will look hard for, and expect to find, other violations of the hazardous waste regulations.
Training for Recordkeepers
RCRA regulations do not contain specific instructions concerning the training required of personnel engaged in recordkeeping activities. However, generators of hazardous waste are required to provide training that prepares employees involved in hazardous waste management activities that ensures the facility’s compliance with the regulations. This means that personnel creating and maintaining records must be properly trained to do perform these tasks competently and accurately.
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