Common Waste Generator Inspection Violations: Recordkeeping Edition

For generators of hazardous waste, being caught unprepared by an unannounced regulatory inspection or audit can have devastating consequences for the health of your business. Regardless of generator status, taking a proactive approach that addresses areas of noncompliance and nonconformance, with periodic evaluations and process adjustments, is crucial for a successful waste management program.

This article will discuss some of the most common recordkeeping violations that waste generators receive. Use this information to take a hard look at your operations and ask yourself, is your facility prepared for an unannounced inspection or audit? 

Waste generator regulatory inspections

An inspection typically consists of a review of recordkeeping practices and an onsite inspection of waste storage areas. While onsite waste storage areas can provide easy fodder for an inspector, it’s essential to review your recordkeeping practices periodically to ensure all required paperwork is easily accessible. 

Many states provide inspection protocols or priority lists, which help review which portions of your waste program are at the highest risk of agency scrutiny. Therefore, always ensure you’re on your hazardous waste regulator’s email distribution list to hear about any recent enforcement actions or regulatory changes that may be relevant to your facility.

Here are the most common waste generator recordkeeping violations: 

• Waste determinations are missing, incomplete, or out-of-date: Don’t just focus on episodic wastes; maintain characterization documentation of your routine wastes like aerosol cans, sludges, and expired products and universal wastes like lamps, batteries, and electronic equipment. In addition, ensure you have a process to be notified when changes to the generation process occur and that your determinations and profiles are updated accordingly.
• Missing, incomplete, or incorrect waste codes or DOT descriptions on manifests: A comprehensive waste determination will ensure you consistently apply waste codes and DOT descriptions on manifests. This information should be uniform across your entire waste recordkeeping process, with the same codes and descriptions on your determination, profile, label, and manifest.
• Missing destination facility copies of manifests: It’s easy to check a waste shipment off your to-do list once it leaves the site, but don’t forget to check with your Treatment, Storage, and Disposal Facility (TSDF) if you don’t receive a completed manifest on time. A consistent waste tracking system helps you keep track of manifest due dates and ensure that copies are sent to state agencies as required.
• Reports or notifications are incomplete or unavailable: While the reports or notifications required for your facility will depend on your location and generator status, record retention requirements will always apply. Ensure copies of your biennial/annual/quarterly reports, periodic SQG notifications, and administrative change or generator status notifications are easily accessible for both EHS and operations staff.
• Missing, incomplete, or incorrect Land Disposal Restrictions: LDRs can easily fall through the cracks as you plan a waste shipment. Work with your Treatment, Storage, and Disposal Facility to ensure an LDR is included in a shipment when required and contains all applicable information, including waste categories, underlying hazardous constituents, and manifest numbers. Remember, this information should always be consistent with your waste characterization. 

Simplifying the recordkeeping process

For generators of hazardous waste, ensuring that your records and waste storage areas are ready for an unannounced inspection or audit is critical to maintaining the health of your business. However, correctly maintaining the documentation and everything else that goes into preserving compliance for waste generators is challenging. Encamp can help. 

Ready to simplify your compliance? Encamp solves the complexity of environmental compliance with high-tech solutions and high-touch expert support and is on a mission to create a world where good for business can equal good for the environment. We help enterprises transform compliance programs and human processes into a technology-driven system that lays the foundation for accurate and ongoing environmental compliance. Request a demo to learn more.