Hazardous Waste Generator Compliance Checklist

This comprehensive hazardous waste generator compliance checklist ensures regulatory compliance with EPA, 40 CFR Part 262, State Hazardous Waste Agency, OSHA. Monthly compliance inspection for Large Quantity Generators (LQGs) and Small Quantity Generators (SQGs) covering satellite accumulation, container labeling, 90-day storage limits, emergency planning, and EPA generator improvements rule requirements per 40 CFR Part 262. Generator non-compliance is among EPA's most frequently cited RCRA viol

  • Industry: Waste Management & Recycling
  • Frequency: Daily / Weekly
  • Estimated Time: 30 minutes
  • Role: Operations Manager / Environmental Compliance Officer
  • Total Items: 17
  • Compliance: EPA, 40 CFR Part 262, State Hazardous Waste Agency, OSHA

Accumulation Area Compliance

Inspect accumulation areas per 40 CFR 262.15-262.17.

  • Are satellite accumulation areas at or below 55-gallon (acute hazardous waste: 1 quart) limits per 40 CFR 262.15?
  • Are satellite accumulation containers located at or near point of generation as required?
  • For LQGs, are no containers exceeding 90-day accumulation limit (SQGs: 270 days) per 40 CFR 262.17?
  • Are all accumulation containers closed when not actively adding waste per 40 CFR 262?
  • Is secondary containment in place under liquid hazardous waste containers in central accumulation area?

Container Labeling and Marking

Verify labeling per 40 CFR 262 and DOT 49 CFR 172.

  • Is 'Hazardous Waste' label with EPA waste code and composition on all accumulation containers?
  • Is accumulation start date marked on all containers in central accumulation area per 40 CFR 262.17?
  • Are containers meeting DOT marking, labeling, and packaging requirements before off-site shipment?
  • Are universal waste streams (batteries, lamps, pesticides) labeled per 40 CFR Part 273 universal waste rules?

Emergency Planning and Response

Verify emergency planning per 40 CFR 262.250-265.

  • Is Emergency Coordinator designated and reachable at all times per 40 CFR 262.260?
  • Has facility notified LEPC/SERC of hazardous waste emergency coordinator per EPCRA Section 302?
  • Is contingency plan or emergency procedures document current and available to emergency responders?
  • Is spill kit stocked and personnel trained on first responder awareness level for chemical releases?

Manifests and Off-Site Shipment

Verify manifest compliance per 40 CFR 262 Subpart B.

  • Is EPA Uniform Hazardous Waste Manifest completed and submitted via e-Manifest per 40 CFR 262.20?
  • Is hazardous waste transported only by EPA-licensed hazardous waste transporter?
  • Is waste shipped only to licensed RCRA-permitted TSDFs?
  • If manifest acknowledgment not received within 35 days, has exception report been filed per 40 CFR 262.42?

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Why Use This Hazardous Waste Generator Compliance Checklist?

This hazardous waste generator compliance checklist helps waste management & recycling teams maintain compliance and operational excellence. Designed for operations manager / environmental compliance officer professionals, this checklist covers 17 critical inspection points across 4 sections. Recommended frequency: daily / weekly.

Ensures compliance with EPA, 40 CFR Part 262, State Hazardous Waste Agency, OSHA. Regulatory-aligned for audit readiness and inspection documentation.

Frequently Asked Questions

What does the Hazardous Waste Generator Compliance Checklist cover?

This checklist covers 17 inspection items across 4 sections: Accumulation Area Compliance, Container Labeling and Marking, Emergency Planning and Response, Manifests and Off-Site Shipment. It is designed for waste management & recycling operations and compliance.

How often should this checklist be completed?

This checklist should be completed daily / weekly. Each completion takes approximately 30 minutes.

Who should use this Hazardous Waste Generator Compliance Checklist?

This checklist is designed for Operations Manager / Environmental Compliance Officer professionals in the waste management & recycling industry. It can be used for self-assessments, team audits, and regulatory compliance documentation.

Can I download this checklist as a PDF?

Yes, this checklist is available as a free PDF download. You can also use it digitally in the POPProbe mobile app for real-time data capture, photo documentation, and automatic reporting.

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