Hazardous Waste Compliance Assistance | Common Violations & How to Prevent Them
Violations of hazardous waste regulations can be costly for those who manage hazardous waste and harmful to the environment. Following are some of the most common hazardous waste violations, along with links to requirements and best practices to help you stay in compliance and prevent potentially costly product loss and/or cleanups.
Improper Container Management
Improperly labeled and open hazardous waste containers can result in overflows, spills, confusion among employees and waste haulers, and potentially illegal disposal of hazardous waste. Ensuring the labels are properly affixed and contain accurate information is one part of an efficient hazardous waste management system.
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Lack of Waste Determination
Waste determinations are required in order to decide whether a material is a solid waste, hazardous waste, or neither. Waste cannot leave the facility without a proper waste determination. The only way to determine the correct disposal method for the waste is to ensure facility representatives know exactly what hazards the material may pose.
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Improper Treatment, Storage or Disposal
Unless an exclusion is claimed, treatment, storage, and/or disposal of hazardous waste is illegal without a Resource Conservation and Recovery Act (RCRA) permit. Treating, storing, and/or disposing of hazardous waste should only occur at Treatment, Storage, and/or Disposal Facilities (TSDFs) that have been approved by ADEQ. If a facility claims an exclusion, they must document exactly how they are complying with requirements.
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Improper Universal Waste Management
Universal waste typically has hazardous characteristics and must be handled with care. Lamps such as fluorescent light tubes contain mercury vapor that releases into the environment if the glass is broken. Many batteries contain acid and toxic metals such as lead. These items can be managed and recycled as universal waste, but cannnot be disposed to a landfill.
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Unmet Procedural Requirements
Employees who are untrained or inadequately trained in hazardous waste and universal waste management tend to cause deficiencies around the facility that are noticed during compliance inspections.
Preparedness and Prevention Measures
Preparedness and prevention measures ensure that the facility is set up properly for emergency responders to do their jobs in the event of an incident at the facility.
Contingency Plan & Emergency Procedures
The contingency plan and emergency procedures requirements ensure that employees are prepared to keep themselves safe in the event of an incident. They also ensure that the emergency coordinators know their duties regarding communication with employees and first responders.
Developing and maintaining procedures for hazardous waste management | Learn More >