Hazardous Waste
- Do you know if solid wastes are generated at the facility?
- If solid wastes are generated at the facility, have you listed the following information:
–Type of waste?
–Quantity?
–Result of which process?
–Storage, if any?
–Disposition?
- Are characteristic hazwastes generated at the facility?
- If characteristic hazwastes are generated at the facility, have you listed the following information:
–Type of waste?
–Quantity?
–Result of which process?
–Storage, if any?
–Disposition?
Water Quality
- Does your company have a National Pollution Discharge Elimination System (NPDES) permit?
- Is your site or facility covered under a NPDES Stormwater permit?
- Do you know whether your company is disposing of any chemicals in wastewater that are not covered by the NPDES permit?
- Is pollution control equipment being properly maintained?
- Is your company monitoring wastewater properly?
- Do you know whether any variations in effluent are not accounted for by production changes?
Spill Prevention and Control
- Is your facility required to have a Spill Prevention, Control, and Countermeasure Plan (SPCC Plan?)
- Have you provided required secondary containment for containers and vessels?
- Is your spill prevention equipment being properly maintained?
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Air Quality
- Does your facility have the appropriate construction and/or operating air emissions permits?
- Is emissions control equipment being maintained properly?
- Do you know if any permit violations have occurred?
- Have you checked to find out if any other requirements apply?
- Is the facility located in a nonattainment area?
- Is the facility a “major source”?
- Is the faciltiy a “synthetic minor source”?
- Is the facility a “natural minor source”?
- Are the facility’s air emissions being accurately quantified and documented in an air emissions
- inventory?
- Is the air emissions inventory being compiled according to the frequency outlined in any applicable
- permit?
- Is each piece of equipment in compliance with the terms and conditions of its permit?
Asbestos
- Do you know if friable asbestos is present?
- If friable asbestos is present, do you know where it is located?
- Do you know if air sampling is being conducted?
- Have your engineering controls been put in place?
- If your engineering controls have been put in place, are you aware of any warning signs of
- contamination?
- Is medical surveillance being done?
- Do you know who keeps medical records?
Toxic Substance Control Act (TSCA)
- Do you know whether your company manufactures or imports any chemicals not listed on the
- chemical inventory?
- Have premanufacture notices been submitted?
- Do you know whether your company has or uses any chemicals banned under the TSCA?
- Do you know who is responsible for keeping the required records?
Community Right to Know
- Do you know what you are required to do under the following provisions:
- Superfund Amendments and Reauthorization Act (SARA) Title III, Section 311: material safety
- data sheets (MSDS)?
- SARA Title III, Section 312: Tier I/Tier II?
- SARA Title II, Section 313: toxic chemical release forms?
- Do you know what required reporting has been completed under the following provisions:
- Superfund Amendments and Reauthorization Act (SARA) Title III, Section 311: material safety
- data sheets (MSDS)?
- SARA Title III, Section 312: Tier I/Tier II?
- SARA Title II, Section 313: toxic chemical release forms?
- Do you know who is responsible for the required reporting under the following provisions:
- Superfund Amendments and Reauthorization Act (SARA) Title III, Section 311: material safety
- data sheets (MSDS)?
- SARA Title III, Section 312: Tier I/Tier II?
- SARA Title II, Section 313: toxic chemical release forms?
- Has your workplace been evaluated for hazardous chemicals?
- Have you checked to see that hazardous chemical containers are labeled properly?
- Have MSDSs been obtained or developed?
- Do you know where the MSDSs are located?
- Are you familiar with the required recordkeeping under each of the following:
- RCRA?
- CWA?
- CAA?
- Asbestos?
- TSCA?
- Community Right-to-Know?
- Worker Right-to-Know?
- Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)?
- Applicable state laws?
- Each valid permit for the facility?
- Do you know which person or department is responsible for the required recordkeeping under each of the following:
- RCRA?
- CWA?
- CAA?
- Asbestos?
- TSCA?
- Community Right-to-Know?
- Worker Right-to-Know?
- Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)?
- Applicable state laws?
- Each valid permit for the facility?
Properly preparing for a regulatory agency visit and conducting self-inspections are crucial to avoiding enforcement actions. Get ready with the all new report, Inspection Requirements for EHS Managers. Get it now.
Worker Right to Know