Has the facility identified all of its hazardous waste streams?
Conformance will be determined based on: review of production processes, type of wastes generated at these processes and whether or not the facility has made hazardous waste determinations on all waste streams.
NOTE: This is something inspectors do routinely. Interns may need to bring back process or other information to discuss with the state project lead in order to answer this question.
Emergency Response Indicators
Is the facility required to have emergency procedures?
IF NO, SKIP to Question 20b
If yes, is the facility in compliance with the applicable requirements for emergency procedures for this category of generator?
Compliance is based on individual state requirements for this category of generator.
If emergency procedures are not required, does the facility have emergency procedures in place?
Visual inspection and inquiry into whether the information is up to date.
NOTE: Emergency procedures can include: The facility posting the current name and telephone number of the emergency coordinator; Posting the location of fire extinguishers and spill control material, and if present, fire alarm; Posting the telephone number of the fire department, unless the facility has a direct alarm.
Does the facility have an employee training program that teaches employees proper hazardous waste management procedures?
Inspector will ask facility to describe program as well as ask to see any documentation. The compliance verification will be to determine if the facility is following the practice of having an employee training program. If the facility demonstrates its existence, then the requirement is met. We will not evaluate the “quality” of the training program.
Is there any indication of spills in or near the shop?
Inspector will check for stains on the ground and in and around manholes, leaking tanks and containers and/or pooled liquids.
The States Common Measures Project Final Report