EPA RCRA Hazardous Waste Compliance

Evaluate Resource Conservation and Recovery Act compliance for hazardous waste generation, storage, treatment, and disposal in laboratory and manufacturing environments

BiotechPharmaResearchManufacturing25 minutes18 questions

1. Generator Status

Have you determined your EPA generator category (VSQG, SQG, or LQG)?*

Generator category based on monthly hazardous waste quantity: VSQG (<100kg), SQG (100-1000kg), LQG (>1000kg)

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

40 CFR 262.12: Obtain EPA ID before generating/transporting hazardous waste

2. Waste Characterization

Is all waste properly characterized as hazardous or non-hazardous?*

40 CFR 262.11: Generator knowledge or testing to determine if waste is hazardous

Are listed (F, K, P, U) and characteristic (D) waste codes identified?*

Listed wastes from specific/non-specific sources, characteristic wastes (ignitable, corrosive, reactive, toxic)

Are satellite accumulation areas (SAAs) used for initial waste collection?*

40 CFR 262.15: Up to 55 gallons per SAA at/near point of generation under operator control

3. Accumulation & Storage

Are containers properly labeled with "Hazardous Waste" and accumulation start date?*

40 CFR 262.34: Label with words "Hazardous Waste", waste identity, hazard class, accumulation start date

Do you comply with accumulation time limits (90/180/270 days)?*

LQG: 90 days, SQG: 180 days (270 if >200 miles to TSDF), VSQG: no time limit but quantity limits

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

40 CFR 262.34(a)(1)(i): Containers must be closed during storage except when adding/removing waste

Are incompatible wastes segregated?*

40 CFR 262.34(a)(1)(iv): Separate incompatible wastes (acids/bases, oxidizers/organics)

4. Manifesting & Transportation

Do you use EPA Uniform Hazardous Waste Manifests for offsite shipments?*

40 CFR 262 Subpart B: Manifest tracks waste from cradle to grave

Are transporters and TSDFs (Treatment/Storage/Disposal Facilities) EPA-permitted?*

Only ship to permitted facilities, use registered transporters with EPA ID

Do you track exception reports for missing signed manifests?*

40 CFR 262.42: Exception report if signed manifest not received within 35/45 days (LQG/SQG)

5. Training & Emergency Response

Is hazardous waste training provided to personnel annually?*

40 CFR 265.16: Initial training within 6 months of hire, annual refresher

Is a contingency plan and emergency procedures in place?*

40 CFR 262.34(d)(5): SQG/LQG must have emergency procedures, coordinate with local responders

Are spill cleanup materials and emergency equipment accessible?*

Spill kits, PPE, fire extinguishers, eyewash/safety showers near waste areas

6. Recordkeeping & Reporting

Are manifests, test results, and waste determinations retained per regulations?*

40 CFR 262.40: Retain manifests, biennial reports, exception reports for 3 years

Do LQGs submit biennial reports (EPA Form 8700-13A)?*

40 CFR 262.41: LQG only, report waste generation and management activities every 2 years

Are waste minimization efforts documented?*

Pollution Prevention Act: Certification on biennial report, SQG written waste minimization program

Please answer all required questions to see your results