Proper Hazardous Waste Management Indicators
At the time of inspection, has the facility exceeded the state’s time limits for the amount of RCRA hazardous waste that can be stored on-site by this category generator (excludes satellite accumulation)?
As applicable, inspector will verify conformance based on dates on containers which detail when accumulation begins (if no containers are labeled, then inspector will circle: no labels.
NOTE: Some states have no time limits depending on the generator category. If this is the case circle NA.
At the time of the inspection, has the facility exceeded the state’s accumulation limits for hazardous waste for this category of generator (excludes satellite accumulation)?
As applicable, inspector will inventory all hazardous waste accumulated on-site in containers and tanks to determine total weight of waste being accumulated at one time.
NOTE: Some states have no accumulation limits. If this is the case circle NA.
Is a manifest required for this type of facility to ship hazardous waste?
IF NO, SKIP to Question 18b
If yes, does the facility use a hazardous waste manifest to ship its hazardous waste when a manifest is required?
Inspector will look at one (1) year of manifest records as well as ask the facility if they have kept three (3) years of records. If there are gaps in the shipments or shipping records, the inspector will ask facility to explain gaps. Inspector will use professional judgment to determine if explanation of gaps is valid.
NOTE: The word “look” in this case means that the inspector will confirm that all shipments have been manifested and not that each and every manifest was filled out correctly.
If a hazardous waste manifest is not required, does the facility document its hazardous waste shipments, e.g. non-hazardous manifest, bill of lading, other documentation?
Inspector will ask to see documentation.
NOTE: Circle NA for facilities that use a hazardous waste manifest.
The States Common Measures Project Final Report