If you are generating hazardous waste, it is important to know the recordkeeping requirements that must be followed according to the Resource Conservation and Recovery Act (RCRA). These requirements include maintaining records of waste determinations, manifests, and storage times, as well as documenting employee training and emergency preparedness plans. Adhering to these requirements can help ensure compliance with environmental regulations and prevent potential penalties and liabilities. For more details, check now!

1. Recordkeeping Requirements
for Hazardous Waste
Generators
Generating Hazardous Waste?
Know the Recordkeeping Requirements that
must be Followed According to the RCRA.

2. All employers must safeguard the health of individuals exposed to
or handling hazardous waste. To instill greater diligence in this
regard, the U.S. Environmental Protection Agency (EPA) under the
Resource Conservation and Recovery Act (RCRA) has developed
and implemented a set of rules and regulations that must be
complied with.
Take a look at the summarized table of recordkeeping
requirements for LQGs, SQGs, and VSQGs.
Introduction

3. All sizes of waste generators can benefit from keeping proper and
detailed records, However, the larger the amounts of hazardous
waste being handled, the more stringent the recordkeeping
requirements. As such, the RCRA gives detailed guidance on
recordkeeping requirements for hazardous waste generator
facilities.
Let’s discuss these recordkeeping requirements in detail:
What Types of Recordkeeping
are Required by the RCRA?

4. Job titles for positions related to hazardous waste.
Names of employees holding these positions.
Written job descriptions with specific information.
Written descriptions of the type and amount of training provided.
Documentation confirming successful completion of the training, such as a certificate
of training.
Hazardous waste personnel at LQGs must receive initial and annual re-training, as per the
regulations (262.17(a)(7)(iv)), and these training sessions must be documented.
According to 40 CFR Part 262.17(a)(7)(v), the following records pertaining to training must
be maintained by large quantity generators:
1. Employee training records

5. Results of any tests, sampling, analyses, or other determinations.
Documentation of the methods used for the tests, sampling, analyses, etc.
Records showing the process that generated the waste.
The waste's composition and properties.
All relevant waste codes, such as D001, D002, F003, etc.
Maintaining complete and accurate waste determination records is crucial to keep track of
the composition of the waste, its origin, applicable treatment standards, and potential
exclusions.
According to 40 CFR Part 262.11(f), the following details must be recorded about the waste
determination process:
2. Waste classification records

6. In the United States, the Uniform Hazardous Waste Manifest is utilized as a means of
monitoring the transportation of hazardous waste. Once a generator has received a
signed copy from the receiving facility (i.e., a treatment, storage, and disposal facilities
(TSDF)), that particular copy must be preserved as a record for a minimum of three
years from the date on which the waste was accepted by the initial transporter.
To align with the increasingly tech-savvy world and transition to paperless systems and
processes, the EPA launched the electronic manifest (e-Manifest) option for hazardous
waste generators on June 30, 2018. For more information about the e-manifest
systems, click here.
3. Hazardous waste manifests

7. Large quantity generators are required to have an RCRA contingency plan to ensure that
emergency responders and personnel have access to accurate and current information to
guide their emergency response efforts. Additionally, LQGs must create a quick reference
guide for their contingency plan that includes eight (8) specific elements.
The regulations governing the purpose, content, and distribution of written contingency
plans can be found in 40 CFR Part 262, Subpart M.
4. Hazardous waste contingency
plan

8. Name, address, and telephone number of the generator.
Date, time, and type of incident (e.g., fire, explosion).
Name and quantity of the hazardous material(s) involved.
Information about injuries, if any.
An assessment of actual or potential hazards, where applicable.
Estimated quantity and disposition of the recovered material resulting from the
incident.
If an incident involving hazardous waste necessitates the activation of the
contingency plan, the generator is required to document the event's date, time, and
specifics.
This incident report should include the following details:
5. Hazardous Waste Incident
Reports

9. The RCRA regulations establish a hazardous waste management system from the point
of generation to final disposal, known as cradle-to-grave. Even after the hazardous
waste is disposed of, records pertaining to compliance with land disposal restrictions
must be retained. Hazardous waste generators are required to keep copies of LDR-
related records for a minimum of three years after the waste is sent for treatment,
storage, or disposal.
The Land Ban Form, Compliance Certifications, One-time Notice to File, and Waste
Analysis Plans are some of the documents that must be prepared by hazardous waste
generators. For more information about these LDR recordkeeping documents, refer to
40 CFR Part 268.7(a).
6. Land Disposal Restrictions
(LDR) Documentation

10. Hazardous waste generators are required to regularly inspect the tank and central
storage areas as per the 40 CFR Parts 262 and 265. The regulations also mandate
recordkeeping of the daily tank inspections.
The facility should retain tank inspection records until it ceases operation. Additionally,
according to 40 CFR Parts 265.191(a) and 192(a) and (g), LQGs are required to keep an
engineer's evaluation of the storage tank system's integrity until the facility closes.
7. Records for Tank and Central
Storage Area Inspections

11. The EPA ID number of the facility,
The name and address of the facility,
The quantity and type of hazardous waste generated, and
Whether the hazardous waste was sent for recycling, treatment, storage, or disposal.
According to Federal hazardous waste regulations, LQGs are required to submit a
Biennial Report every even-numbered year (2024, 2026, etc.) by March 1st. This report
must detail the type, quantity, and disposition of hazardous waste(s) generated or
stored during the previous year.
As part of the Biennial Report (EPA Form 8700-13A/B), generators are required to
provide specific details, such as:
8. The Biennial Report

12. While recordkeeping is important when generating hazardous waste, equally
important is the need to provide training to employees and other workers
involved in handling hazardous waste in organizations across all types of
industries that produce hazardous waste. Thus, employers must provide RCRA
initial and annual refresher training to workers in their facilities to comply
with regulations and protect the health of workers.
Additionally, any organization involved in the treatment, storage, and disposal
of hazardous waste must train employees according to the HAZWOPER
standards.
Training Requirements According
to the RCRA

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