Hazardous Waste Recordkeeping Checklists for RCRA, Exporters, and Land Bans

Here’s a quick checklist of the paperwork you should have for your RCRA, hazardous waste exporting, and land ban requirements.

RCRA

Have you kept the following hazardous waste records for specified periods of time (if applicable)?

1. Copies of a small quantity generator’s “reclamation agreement” for at least 3 years after the agreement’s termination or expiration (40 CFR 262.20(e)(2))?
2. Manifests for at least 3 years after the date the waste was accepted by the initial transporter (40 CFR 262.40(a))?
3. Biennial reports or exception reports for at least 3 years from the due date of the report (40 CFR 262.40(b))?
4. Records of any test results, waste analyses, or other determinations made in accordance with 40 CFR 262.11 (hazardous waste determination) for at least 3 years since the hazardous waste was last sent for on-site or off-site treatment, storage, or disposal (40 CFR 262.40(c))?

Hazardous Waste Exporters

1. Do you have copies of notification of intent to export, EPA acknowledgment of consent, and consignee confirmation for at least 3 years from the date the hazardous waste was accepted by the initial transporter (40 CFR 262.57)?
2. Have you kept copies of the annual report for at least 3 years from the report’s due date (40 CFR 262.57)?

Land Ban

1. As a generator, have you kept copies of all notices, certifications, demonstrations, waste analysis data, and other documentation required under 40 CFR 268.7 at least 3 years from the date the waste was last sent for treatment, storage, or disposal on-site or off-site (40 CFR 268.7(a)(8))?
2. If you manage prohibited wastes that are excluded from the definition of hazardous or solid waste or are exempt from land disposal restrictions under 40 CFR 261.2 to 261.6, have you submitted into the facility’s file the one-time notice regarding hazardous waste generation, subsequent exclusion or exemption, and disposition?