1. Safety records were covered in the February 2015 issue,
but what about environmental records? If you have the stor-
age space, keep environmental records for the life of your
business. If you are running out of space, here are the mini-
mum amounts of time to keep environmental records.
In most cases, you must keep hazardous waste records
for three years and air regulation records for five years.
Records can be hard copies or electronic and must be legible.
You must be able to make hazardous waste records immedi-
ately available to an inspector. MPCA air permit records can
be moved to a central office after one year, but must be made
available to an inspector in a reasonable amount of time.
License or permit applications. Keep copies of haz-
ardous waste license applications and supporting documents
for three years. Keep copies of an air permit application,
change forms and supporting documents as long as you have
the permit and for five years after.
Hazardous waste evaluation records. Keep hazardous
waste evaluation records as long as your shop generates the
waste and for three years after the last time the waste is
shipped. Your evaluation records might include lab test re-
sults, product information or manufacturer certifications. If a
consultant or transporter made the evaluation for you, keep a
copy of the reasoning or method they used, such as lab test
results, as well as the final determination.
Manifests and shipping records. Keep copies of mani-
fests, shipping records and related documents for at least
three years after the waste is shipped. The Minnesota Pollu-
tion Control Agency recommends keeping manifests for the
life of your business and beyond. This is because your busi-
ness’s hazardous waste liability lasts forever, and manifests
are proof that wastes reached their intended destinations.
Shipping records at your shop might include those from
shipping used oil or rags, Very Small Quantity Generator col-
lection center receipts or pumping receipts. Related docu-
ments might include manifest exception reports or land
disposal restriction notices.
Weekly hazardous waste inspection logs. Keep haz-
ardous waste inspection logs for three years. If you keep the
log sheets close to the hazardous waste storage area for con-
venience, make sure to file the completed log sheets so they
don’t get lost or damaged.
Air permit requirements. If you have an air permit,
keep a copy of the permit for the life of the permit and keep
related records for five years. Records might include emis-
sions calculations, emissions inventory submittals, support-
ing documents such as VOC reports from your paint vendor,
records of equipment changes and any required monitoring.
If you have calculations that show you don’t need an air per-
mit, keep them for the life of the business.
Emergency planning notifications, if required. Keep
emergency planning notification documents as long as they
are current and for three years after. Small and large quantity
hazardous waste generators must notify local emergency
Environmental Recordkeeping
PARTNERS IN PREVENTION
June 2015 19AASP News
continued on pg. 21
LET US
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Contact
AASP-MN News
Sales Director
Alicia Figurelli
973.667.6922 /
ALICIA@GRECOPUBLISHING.COM
AASP0615.qxp_AASP News 5/18/15 2:55 PM Page 19