Preparing a hazardous waste inspection to-do list before the end of the year, is a good way for hazardous waste generators to ensure that their facilities or organizations comply with regulations. Yet, more than compliance issues, a year-end to-do list helps facilities organize and review their waste management practices, verify records are accurate, work to improve safety, and confirm that all regulatory obligations have been met to avoid penalties, providing a clean slate for the upcoming year. The list can help identify discrepancies or non-compliance with regulations, allowing prompt corrective action before the start of the new year.
A year-end to-do list is not all that dissimilar from a hazardous waste inspection checklist that generators are ready for EPA visits. However, unlike a checklist, which is typically a more detailed, step-by-step list that ensures specific actions are completed, an end-of-year to-do list may include diverse items with varying levels of complexity. To ensure the transition to a new year is smooth, here are six items generators should have on every end-of-year hazardous waste inspection to-do list.
1. Verify Proper Storage and Handling Standards
The inspection to-do list should verify that hazardous materials are stored and handled by federal and state regulatory standards and requirements. When inspectors arrive, they assess factors such as labeling, the condition of the containers, storage areas, and storage conditions, ensure incompatible wastes are segregated, check accumulation start dates for the waste, and review daily inspection logs, among other standards.
2. Update Records and Documentation
Another item to have on your year-end hazardous waste inspection to-do list is to verify the accuracy of records and documentation, ensuring they are all up-to-date. Essential documents—such as waste manifests, disposal records, training certificates, and storage logs—cover every aspect necessary for compliance with regulatory requirements. A systematic, organized approach reduces the likelihood of oversight and helps identify any inconsistencies or omissions in record-keeping.
3. Personnel Training Requirements
Regulatory agencies require personnel involved in hazardous waste management to complete specific training to correctly handle, store, and dispose of hazardous materials and understand emergency response procedures. Your facility’s year-end to-do list must document that all relevant employees have completed up-to-date training. This would include any job title and employee name for each position associated with hazardous waste, a written job description for each position, and all training records.
4. Contingency Plans
Contingency plan requirements are a must for an end-of-year inspection to-do list because they ensure a facility is prepared to respond effectively to emergencies, such as spills, fires, or releases of hazardous waste. What’s more, a well-documented and regularly reviewed contingency plan is mandated by regulations. It should verify that emergency contact information, response procedures, and evacuation plans are current and accessible. Plus, a regular review of the plan ensures that all personnel are familiar with their roles during emergencies and that any new risks or facility changes are addressed in the plan should a hazardous situation arise.
5. Annual Report
Another item to add to the to-do list for generators in Maine is the annual Hazardous Waste Report. Generators of hazardous waste in Maine must submit an annual Hazardous Waste Report to the state’s Department of Environmental Protection (DEP) each year. The DEP provides organizations with a yearly Hazardous Waste Report form and instructions. Reports cover the previous year’s hazardous waste activity, including the generation, storage, and disposal of hazardous waste. They must be submitted to the DEP by March 1 each year. The DEP uses this information to track and monitor hazardous waste generation and disposal in the state, and ensure facilities comply with federal and state regulations. Copies of the report must be kept onsite for at least ten years.
6. End-of-Year Disposal
As the year closes, taking care of any outstanding waste onsite that needs proper disposal is a good idea. Hazardous waste generators should consider end-of-year disposal for any outstanding waste to ensure compliance with storage time limits and reduce potential risks associated with prolonged storage. Hazardous waste regulations impose strict timeframes on how long waste can be stored onsite based on generator status. Failure to meet these timelines can lead to regulatory penalties and increased inspection scrutiny. End-of-year disposal also helps minimize safety and environmental risks by reducing the volume of hazardous materials stored, lowering the potential for leaks, spills, or other incidents. From a practical standpoint, clearing out waste at year-end simplifies record-keeping and inventory management, providing a clean and compliant start for the new year.
Contact the Experts at MLI Environmental
Generators are assured of a smooth transition into the new year by developing a hazardous waste inspection to-do list at the end of the year. If your organization has any questions or needs assistance compiling a year-end hazardous waste inspection to-do list, contact the experts at MLI Environmental today. Our team of professionals can assist you with a wide range of services to ensure ongoing compliance and proper management of hazardous waste any time of the year.