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HAZARDOUS WASTE REGULATORY COMPLIANCE

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Introduction

This article is intended to provide a starting point regarding hazardous waste generation and applicable regulatory compliance. An overview of the key hazardous waste regulations are discussed, and then a self-audit questionnaire lets you track the applicability of some macro noncompliance issues to your business. Viewpoint Technical Group also writes database applications to manage this and other types of self-audit information. According to the U.S. EPA, the top reason for noncompliance is a company’s insufficient knowledge base of regulation applicability.

Regulatory Overview

The Resource Conservation and Recovery Act (RCRA) was authorized in 1976. The primary purpose of the act and amendments is to set a framework for the management of hazardous wastes (Subtitle C) and non-hazardous wastes (Subtitle D). The United States Environmental Protection Agency (U.S. EPA) regulates RCRA under Title 40 of the Code of Federal Regulations (CFR): Protection of the Environment, Chapter I: Environmental Protection Agency, Subchapter I: Solid Wastes, Parts 239 through 299. In general, the more common solid waste regulations are found within Parts 239 through 258, and the hazardous waste regulations within Parts 260 through 265.

The identification and listing of hazardous wastes is described in Part 261. Characteristically hazardous wastes are based on ignitability, reactivity, corrosivity, and toxicity as described in Subpart C. Listed hazardous wastes are derived from non-specific sources, specific sources, discarded commercial materials, residues, and acutely hazardous wastes as described in Subpart D.

The standards applicable to generators of hazardous wastes are described in Part 262. There are subparts specific to regulations covering manifesting, pre-transportation, record keeping and reporting, exporting, and importing. Standards pertaining to transporters are covered in Part 263, and standards for hazardous waste treatment, storage, and disposal facilities are covered in Part 264. The later includes subparts on facility standards, preparedness and prevention, contingency planning and procedures, manifests, records and reporting, and releases.

Self-Audit

The self-audit document is not intended to be an all inclusive hazardous waste generator compliance audit, but rather a starting point for further examination of macro noncompliance issues. Print out the PDF, and simply place a check mark in the appropriate column that best answers each question.