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Five Common RCRA Violations to Avoid

Posted by Shivi Kakar

Jun 18, 2013 9:11:00 AM

5_common_rcra_violationsThe Resource Conservation and Recovery Act (RCRA) was passed in 1976 with the goal of outlining the proper disposal of solid and hazardous waste. We often hear of big offenders paying out millions in fines for violations. However, companies are fined for smaller violations every day. It may not be newsworthy, but we understand that even a small fine can put a hardship on a small or mid-size business. Consider five common RCRA violations. 

  1. Failure to Mark Containers. You and your employees may know where you store hazardous waste, but the RCRA requires that the containers be properly labeled. Have labels on-hand and mark containers before any waste is even deposited. Be sure the label notes the accumulation start date, since excluding it is also a violation. Do your research to find out what type of label your state requires since standards vary. Lastly, remember to keep lids on containers at all times and do not use damaged containers.
  2. Exceeding the SAP Limit. RCRA allows you to store up to 55 gallons of waste at a Satellite Accumulation Point (SAP), usually a spot at or near the production line. Be sure your operator understands this and the waste gets moved appropriately before it reaches the limit. 
  3. Keeping Waste Too Long. The storage limits are 90 days for a LQG (large quantity generator) and 120 days for a SQG (small quantity generator). Don't push the limit. Plan on shipping out every two months or every three months, depending on your designation. Remember the less waste on property the less likely you are to have an incident or a violation.
  4. Not Inspecting. RCRA requires weekly inspections. Make a checklist that is inclusive, but simple. Have a process in place to correct any violations immediately. Review the prior week's violations as part of the current week's inspection to ensure any deficiencies have been corrected.
  5. Failing to Train. All new employees who will handle hazardous waste must receive training within six months of their start date. Until the training is complete, they cannot handle hazardous waste unless supervised. Additionally, all employees must attend a refresher class each year. Be sure to keep a record of the training and have employees sign-off that they attended.

While these are five common violations, RCRA requirements are much more in-depth. Emilcott has more than 25 years experience helping companies with RCRA and EPA compliance. Contact us for an assessment. 

Topics: Emilcott, Resource Conservation and Recovery Act (RCRA), Five Common RCRA Violations, RCRA Violations

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