EPA Hazardous Waste Management (RCRA)

Evaluate Resource Conservation and Recovery Act (RCRA) compliance for research and biotech labs generating hazardous waste, covering waste identification, generator requirements, and disposal

BiotechResearchHealthcarePharma20 minutes20 questions

1. Waste Identification & Characterization

Do you properly identify and characterize all waste streams as hazardous or non-hazardous?*

40 CFR 262.11: Determine if waste is RCRA hazardous (listed or characteristic)

Do you test or use process knowledge to determine if waste exhibits hazardous characteristics?*

Characteristic wastes: Ignitability (D001), Corrosivity (D002), Reactivity (D003), Toxicity (D004-D043)

Are listed hazardous wastes (F, K, P, U lists) properly identified?*

40 CFR 261: F-list (non-specific sources), K-list (specific sources), P/U-list (discarded chemicals)

Are hazardous waste containers labeled with contents, hazards, and accumulation start date?*

40 CFR 262.34: Label "Hazardous Waste", contents, hazards, date

2. Generator Status & Requirements

Have you determined your generator status (VSQG, SQG, LQG)?*

VSQG: <100 kg/month, SQG: 100-1000 kg/month, LQG: >1000 kg/month

Do you have an EPA ID number (required for SQG/LQG generators)?*

40 CFR 262.12: EPA ID required before treating, storing, or disposing hazardous waste

If LQG, do you have a written contingency plan and emergency coordinator?*

40 CFR 262.34(d)(5): LQG emergency preparedness requirements

3. Waste Accumulation & Storage

Are hazardous waste accumulation areas properly designated and managed?*

40 CFR 262.34: Satellite accumulation area (SAA) at point of generation

Do you comply with accumulation time limits for your generator status?*

VSQG: no limit (if <1000 kg), SQG: 180 days, LQG: 90 days

Are waste containers in good condition, compatible with contents, and kept closed?*

40 CFR 262.34(a)(1): Containers structurally sound, closed except when adding waste

Are incompatible wastes segregated to prevent reactions?*

40 CFR 262.34(a)(1)(iv): Separate acids/bases, oxidizers/organics, water-reactives

Are waste accumulation areas inspected weekly?*

40 CFR 262.34: Weekly inspections for leaks, deterioration, proper labeling

4. Waste Disposal & Transportation

Do you use EPA-authorized hazardous waste transporters and TSDFs?*

40 CFR 262.20: Transporters must have EPA ID, TSDFs must be permitted

Are hazardous waste manifests completed for all off-site shipments?*

40 CFR 262.20: Uniform Hazardous Waste Manifest for tracking cradle-to-grave

Do you maintain waste profiles and ensure wastes meet TSDF acceptance criteria?*

TSDF requirements: Provide waste characterization and analytical data

5. Training & Contingency Planning

Do personnel receive initial and annual hazardous waste training?*

40 CFR 262.34: Training on waste handling, emergency procedures, regulatory requirements

Are emergency response equipment and procedures in place for spills?*

40 CFR 262.34: Spill kits, PPE, communication equipment at accumulation areas

6. Recordkeeping & Reporting

Do you maintain manifests and land disposal restriction (LDR) notifications?*

40 CFR 262.40: Retain manifests for 3 years, LDR notices with manifests

Do you submit biennial reports (if LQG)?*

40 CFR 262.41: LQGs report waste generation and management activities every 2 years

Are waste minimization efforts documented and tracked?*

Best practice: Source reduction, recycling, and waste reduction strategies

Please answer all required questions to see your results