Hazardous waste violations are no laughing matter. Depending on the nature and severity of the violation, you could face hefty fines, civil judicial actions, or even criminal charges and jail time.
It’s hard to run a successful company from behind bars, so we’ve put together a few quick tips to help you stay on the right side of the law.
#1: Label all your containers in your storage areas
If you have containers that are kept in a 90-day or 180-day storage area, they must be marked with the words “Hazardous Waste.” You also have to put the following information on the label:
- the Generator’s Name
- the Generator’s Address
- Accumulation Start Date
- Contents of the container
- Physical state
- and the hazardous properties
#2: Make sure all your containers are kept closed
The only time a container should be opened is when you are adding or removing waste containers. The rest of the time, it should be closed, which includes:
- closing and latching funnels
- screwing in bungs
- using drum rings
- and tightening bolts
Keep in mind, that if the container would spill if it were overturned, then it is considered to be open.
#3: Used oil containers must be properly labeled
Any container holding used oil must be marked with a label that says “Used Oil.” Also, any pipes used to transfer oil to a UST must be marked as “Used Oil.”
Used Oil is defined as any oil that was refined from crude oil, or any synthetic oil, and that is used and as a result of such use, is contaminated by physical or chemical impurities. If you aren’t sure if your oil is considered “used oil”, then feel free to contact us and we can help.
#4: Perform weekly inspections of storage areas
It’s important that storage areas be checked regularly for violations. Designate a day each week that you can inspect them, and be consistent. Make sure you have a back-up inspector in place in case the primary person is off work for one reason or another. Require them to keep a log of each inspection that includes the date, time, name of inspector, and any additional information you feel is needed.
#5: Have a safety plan in place
It doesn’t matter if you generate a lot of waste, or a small amount, it’s important to have a plan in place to deal with any issues. This helps you avoid violations, as well as keep your employees, your facility, and the environment safe if there’s trouble.
Designate one person as an emergency coordinator, and assign a back up emergency coordinator as well. Make sure they keep information up-to-date, and on-site, concerning safety and response plans. Also, make sure to document any information submitted to local authorities.
Now… make sure you stay and legal, and if you have questions or need help… we’re a phone call or email away, so just let us know. You can also find more information on Enforcement of Hazardous Waste Regulations on the PDF created by the EPA here: http://www.epa.gov/osw/inforesources/pubs/orientat/rom310.pdf