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How to Avoid Violating the RCRA

The Resource Conservation Recovery Act (RCRA) was first introduced in the 1970s to outline how companies should dispose of solid and hazardous waste. While you are most likely to hear about RCRA violations when companies have to pay out millions in huge fines, there are often far more companies that get smaller fines for violations every day. To avoid being one of those companies that gets a small or large fine, it’s important to understand some of the most common violations that might occur.

 

Improperly Marking Containers

Even if everyone at your company is aware of where the hazardous materials are stored, regulations require that you label these containers in a specific way. Make sure you have these labels on hand if you plan to store hazardous materials, and place the labels on the containers before you put any materials in there. Labels must indicate accumulation start date, and excluding that could be another violation.

 

Storing More Than SAP Limits Allow

If you want to keep any hazardous materials at or near the production line, regulations require that you can only have up to 55 gallons at these Satellite Accumulation Points (SAPs). Make sure your entire team is aware of this limit and moves the hazardous materials to a more permanent storage area before it reaches (and definitely before it exceeds) that limit.

 

Storing Waste for Extended Time Periods

If you are classified as a large quantity generator (LQG) you can store hazardous materials on site for up to 90 days, while small quantity generators (SQG) can store them for up to 120 days. It’s important that you have a plan to get these materials moved off your site before that date, so create a shipping plan to move them every two to three months. You can call a company like Envirocare Hazmat to help you eliminate the hazardous materials and ensure proper disposal.

 

Avoiding Inspections

The RCRA requires companies to conduct weekly inspections, and while you might not think this is necessary, if you are audited and cannot product evidence of these weekly inspections, you could get hit with a fine. Create a simple but inclusive checklist that your employees can use to conduct the inspection, and make sure they understand the process for reporting any problems or violations so you can address them immediately.

 

Skipping Training

Your new employees might not have been in a facility where hazardous materials are stored before, and may be unaware of the regulations for handling and storing these materials. Whenever you have someone new on the team, make sure he or she receives extensive training in the first three to six months of employment (sooner if they have direct exposure to the materials), and have your employee attend refresher courses often. Keep records of training to provide if necessary.

 

If you do need help with storage or disposal of hazardous materials, or training for your employees, Envirocare Hazmat can help.