Container Violations

According to a recent article in the Environmental Ezine, if you are a generator of hazardous waste, the first stop an inspector will likely make when conducting an inspection at your facility is the hazardous waste accumulation or storage area. This might be because there are a few common mistakes generators tend to make in connection with their hazardous waste containers.

The article lists the most common container violations as:

1. Not keeping containers closed. Inspectors often observe hazardous waste drums that have been left open during the entire work shift, or drums with open funnels.

2. No accumulation start date is marked on the container. If you are a generator accumulating hazardous waste on-site without a permit, you must be sure to clearly mark on each container the date which each period of accumulation begins.

3. Failure to document inspections. Generators, as well as, Treatment, Storage, and Disposal Facility (TSDF) owners and operators are required to inspect, at least weekly, areas where containers are stored. These facilities often cannot produce documentation that such inspections took place. Inspectors may ask to review up to 3 years of inspection records.

4. Missing the words “HazardousWaste” on the container. Keep in mind that some states also require additional information on the container, such as the hazardous waste number or chemical name that identifies the container’s contents.

5. Using improper containers, or containers that are in poor condition. Your containers must be in good condition and lined with material that will not react with the stored hazardous waste.

6. Failing to comply with the special satellite accumulation area rules. Generators accumulating hazardous waste on-site without a permit in accordance with the accumulation rules may store up to 55 gallons of hazardous waste, or 1 quart of acutely hazardous waste, in their satellite accumulation area, provided specific requirements are met. Violations include an absence of operator control of the process generating the waste, failure to list the date the satellite container reaches its accumulation limit, and failure to remove the waste from the satellite area within 3 days of exceeding the quantity limitations.

The article concluded by saying that receiving one of these violations will most likely earn you the dubious honor of being known as a facility that will need to be carefully examined by your state environmental agency inspectors in future visits.

Also, a history of noncompliance can affect the severity of future penalties. You can keep your wallets and reputations intact by carefully following the container management rules.