Hazardous Waste Records and Determination of Hazardous Waste
If a company generates waste then they must make an accurate determination of hazardous waste as to whether that waste is a hazardous waste in order to ensure wastes are properly managed according to applicable RCRA regulations. To determine if a waste is hazardous waste or not, the following is a guide:
Determination of hazardous waste must be done at the point of generation, before any mixing, alteration or dilution of the waste takes place. Make sure that the waste determination is performed before any environmental factors have had an influence on the waste or its properties.
Determine whether the solid waste is excluded from regulation under 40 CFR 261.4.
If the waste is not excluded under 40 CFR 261.4, then determine whether the waste meets any of the listing descriptions under subpart D of 40 CFR part 261. Acceptable knowledge that may be used in making an accurate determination as to whether the waste is listed may include waste origin, composition, the process producing the waste, feedstock, and other reliable and relevant information. If the waste is listed, the person may file a delisting petition under 40 CFR 260.20 and 260.22 to demonstrate to the Administrator that the waste from this particular site or operation is not a hazardous waste.
In Determination of Hazardous Waste assess whether the waste exhibits one or more hazardous characteristics.
You must apply knowledge of the hazard characteristic of the waste in light of the materials or the processes used to generate the waste. Acceptable knowledge may include process knowledge (e.g., information about chemical feedstocks and other inputs to the production process); knowledge of products, by-products, and intermediates produced by the manufacturing process; chemical or physical characterization of wastes; information on the chemical and physical properties of the chemicals used or produced by the process or otherwise contained in the waste; testing that illustrates the properties of the waste; or other reliable and relevant information about the properties of the waste or its constituents.
When available knowledge is inadequate to make an accurate determination, the person must test the waste.
Persons testing their waste must obtain a representative sample of the waste for the testing.
Where a test method is specified in subpart C of 40 CFR part 261, the results of the regulatory test, when properly performed, are definitive for determining the regulatory status of the waste.
If the waste is determined to be hazardous, the generator must check the regulations for other possible exclusions or restrictions pertaining to management of the specific waste.
Record Keeping for Hazardous Waste Generators both Small and Large
A small or large quantity generator must maintain records supporting its hazardous waste determinations, including records that identify whether a solid waste is a hazardous waste.
Records must be maintained for at least three years from the date that the waste was last sent to on-site or off-site treatment, storage, or disposal. These records must comprise the generator’s knowledge of the waste and support the generator’s determination.
The records must include, but are not limited to, the following types of information:
- The results of any tests, sampling, waste analyses, or other determinations made in accordance with this section; records documenting the tests, sampling, and analytical methods used to demonstrate the validity and relevance of such tests.
- Records consulted in order to determine the process by which the waste was generated, the composition of the waste, and the properties of the waste
- Records which explain the knowledge basis for the generator’s determination.
Hazardous Waste Numbers for Small and Large Quantity Generators
If the waste is determined to be hazardous, small quantity generators and large quantity generators must identify all applicable EPA hazardous waste numbers (EPA hazardous waste codes) in subparts C and D of part 261 of this chapter.
Prior to shipping the waste off site, the generator also must mark its containers with all applicable EPA hazardous waste numbers (EPA hazardous waste codes).
Hazardous Waste Management Software
HazMat T&T is a hazardous waste management software solution designed for Environmental Service Companies and companies who generate a large quantity of hazardous waste. The solution tracks hazardous waste from cradle to grave aiding compliance, providing accurate waste inventory, increasing waste handling efficiency, reducing risk and also helps manage waste costs. HazMat T&T Hazardous Waste Management Software can be deployed in a number of deployment scenarios, from Large Hazardous Waste Generators, tracking their hazardous waste at their site to Environmental Service and Waste Management Companies using it track and manage hazardous waste at transfer and disposal sites.
Asset Inspection Management Software
IMEC’s Asset Inspection Management Software can be used to manage any type of Asset Inspection. This Asset Inspection Management Software solution can create corrective actions as a result of asset inspection failures for inspections. Corrective actions are allocated to the appropriate persons, with deadlines for resolution which will greatly reduce the time, effort and cost of managing compliance inspections. Implementing an Asset Inspection management software solution, where users using a Mobile App can easily perform inspections in the field aids compliance, reduces risk and standardizes the inspection process within your organization.
IMEC Technologies provides Safety Management Software to increase worker safety and aid compliance. IMEC’s Safety Management Software will manage inspections and audits, provides hazard identification, incident reporting, management of corrective and preventative actions from generation to closure. IMEC provides lock out tag out software solutions that will allow users to create lockout tagout procedures using an intuitive Mobile App and Manage Lockout Tagout Procedures, also the Review and Execution of those Lockout Tagout Procedures using the Mobile App. Annual Lockout Tagout Procedures audits are conducted using a Mobile App. The Mobile Inspection App allow users to perform inspections and audits, for example the system can be used as a Fire Extinguisher Barcode Inspection Software system to manage monthly fire extinguisher inspections and general fire safety inspections and also to record safety observations and manage corrective actions, anywhere and anytime. The solution can be used as a fire extinguisher barcode inspection software system or life safety inspection system to aid compliance in Higher Education, Healthcare, Industrial and Commercial Organizations. Benefits from a Fire Extinguisher Barcode System include the elimination of paperwork and reducing the burden of compliance with regulations such as NFPA, The Joint Commission. The Mobile App can also be used as a Fire Door Inspection App and with the flexible Forms Manager the solution can be used as a Fire Door Inspection Software Solution also. Fire Door Inspection Software is used is large facilities with large quantities of Fire Doors like Hospitals, Universities and also Cruise Ships. The Incident Reporting App allows users to easily and quickly report incidents, hazards and near-misses, these are then sent to the appropriate people for action and are managed to closure. Web Apps provide features such as, setup, management, scheduling tools, analysis, reporting and dashboards etc with the ability to report incidents to government bodies such as OSHA and RIDDOR. HazMat T&T is a hazardous waste management software solution designed for Environmental Service Companies and companies who generate a large quantity of hazardous waste. The solution tracks hazardous waste from cradle to grave aiding compliance, providing accurate waste inventory, increasing waste handling efficiency, reducing risk and also helps manage waste costs. HazMat T&T Hazardous Waste Management Software can be deployed in a number of deployment scenarios, from Large Hazardous Waste Generators, tracking their hazardous waste at their site to Environmental Service and Waste Management Companies using it track and manage hazardous waste at transfer and disposal sites. For more information visit our website www.imectechnologies.com