Hazardous and Solid Waste

The Most Common Container Violations

  • Failure to keep containers closed. Inspectors often observe hazardous waste drums that have been left open during the entire work shift, or drums with open funnels. See this Environmental Daily Advisor post for more information on closed containers.
  • Failure to mark the accumulation start date on the container. Generators accumulating hazardous waste on-site without a permit must be sure to clearly mark on each container the date on which each period of accumulation begins.

What records must be kept on hand and for how long? Find out now with our Free Special Report, Recordkeeping for EHS Managers. Also receive 2 trial issues of BLR’s Environmental Manager’s Compliance Advisor! Download Your Free Report


  • Failure to document inspections. Generators as well as TSDF owners and operators are required to inspect, at least weekly, areas where containers are stored. These facilities often cannot produce documentation that such inspections have occurred. Inspectors may ask to review up to 3 years of inspection records.
  • Containers missing the words "Hazardous Waste" or other required information on the container. Some states also require additional information on the container, such as the hazardous waste number or chemical name that identifies the container’s contents.
  • Using improper containers, or containers in poor condition. Containers must be in good condition and lined with material that will not react with the hazardous waste being stored therein.
  • Failing to comply with the special satellite accumulation area rules. Generators accumulating hazardous waste on-site without a permit in accordance with the accumulation time rules may accumulate up to 55 gal of hazardous waste or one quart of acutely hazardous waste in their satellite accumulation area, provided specific requirements are met. Violations include an absence of operator control of the process generating the waste, failure to list the date the satellite container reaches its accumulation limit (55 gal for hazardous waste or 1 quart of acutely hazardous waste), and failure to remove the waste from the satellite area within 3 days of exceeding the quantity limitations.

Comply with OSHA and EPA recordkeeping requirements with our free report: Recordkeeping for EHS Managers. Also receive 2 free trial issues of BLR’s Environmental Manager’s Compliance Advisor! Download Your Free Report


These violations can result in the state EPA assessing civil and/or criminal penalties, and earn a generator or TSDF owner or operator the dubious distinction of being known as a facility that will need to be carefully examined during future visits by the agency’s inspectors. A history of noncompliance can affect the severity of future penalties too. Handlers should be aware that many inspectors will make the hazardous waste accumulation or storage area their first stop in your facility inspection.

Take a free trial and join the thousands of environmental professionals who have counted on the Environmental Manager’s Compliance Advisor newsletter’s practical advice and best practice case studies for almost 25 years.

As part of your subscription, you will receive a quarterly insert. This added feature, EHS & Your Business, will help you inform senior management and other key decision makers in your company of business-critical developments in the field of environment, health, and safety (EHS).

Each quarterly insert will spotlight one strategic and timely issue as well as briefly highlight the most important EHS legal developments that could affect your business operations, EHS strategy, and EHS ROI.

The practical features in this twice-monthly advisor eliminate the worry that you might miss, or misunderstand, an important new regulation.

For a limited time, also receive the Free Special Report: Recordkeeping for EHS Managers.

Get 2 Free Issues.

1 thought on “The Most Common Container Violations”

Leave a Reply

Your email address will not be published. Required fields are marked *

This site uses Akismet to reduce spam. Learn how your comment data is processed.