Do SQGs Need to Inspect Container Areas If There Are No Containers Present and for How Long Do Weekly Inspection Logs Need to be Kept?

Q. As a small quantity generator (SQGs), we know that our waste containers during the 180-day accumulation period must be inspected weekly. Does the area still need to be inspected weekly when there are no containers? Also, is there a record retention requirement for the weekly inspection log?


A. The area where containers of hazardous waste were once stored does not have to be inspected weekly if there are currently no containers of hazardous waste in that area. Although treatment, storage, and disposal facilities (TSDFs) are required keep a record of their container inspections, SQGs are not required to keep those records. However, it would be a best management practice to do so as having a written record that can be produced if necessary shows that inspections have indeed been done. Since there is no documentation requirement for SQGs, there is no record retention requirement. For facilities that are required to keep inspections, the retention period is three years following the date of the inspection. If you plan to document your inspections, three years or more is a good time period to retain such records.