Being prepared for a hazardous waste audit should always be on a company's mind. After all, if you're always prepared and performing all aspects of your hazardous waste management properly, there will be far less to worry about if and when these audits happen. If you're not prepared, though, you are much more liable to pay fines and face other punitive actions for every violation found. What do you need to do, therefore, to be as prepared as possible?
Hazardous Waste Inspection: How to Get (and Stay) Prepared
Will We Get Warning before a Hazardous Waste Inspection?
In many cases, no! You will not be informed or alerted before a compliance-based inspection. The person leading that inspection will simply show up, ask for the person in charge of your facility, and commence the audit. This can happen at any time.
Because these kinds of inspections can happen without warning, you must be absolutely certain that you comply with all relevant regulations and rules—at all times. Never wing it. Have a thorough, researched hazardous waste management plan, and be diligent about ensuring all employees follow that plan. From using the right hazardous waste label to ensuring you're using the proper containers, this plan should cover every possible contingency.
What Is RCRA Hazardous Waste Anyway? Educating Your Employees
Compliance will be almost impossible to ensure if your employees are not properly educated and trained within the hazardous waste industry. After all, if they don't know what they're dealing with, how can they be expected to properly store, label, transport, or dispose of it?
Make sure all employees are properly trained in everything—from the basics (how to identify RCRA hazardous waste) to specific situations (which hazardous waste labels to use when).
Hazardous Waste Manifests Matter!
A huge part of proper compliance is properly filling out and storing your hazardous waste manifests. These manifests are the documented proof that you have complied with every aspect of the law when transporting hazardous waste away from your site, so they are your biggest asset when attempting to prove to an auditor that your company is by the book.
It's not uncommon for an auditor to ask for every hazardous waste manifest for the last two years' worth of shipments. These documents need to be kept on site—either as hard copies or as electronic copies. In some capacity, you must be able to call up these documents at a moment's notice in order to be considered compliant.
Remember, for the manifests to be correct, the person signing must have the proper training and authorization to do so.
Comply with Your EPA Generator Status
One difficult aspect of full compliance with hazardous waste regulations is that there are different rules based on your EPA generator status. Therefore, if you're a small quantity generator, there are different timeframes, regulations, and fees than apply to a large quantity generator.
The shipment dates on your manifests must correlate to how long you are permitted to store hazardous waste on your site (according to your generator status). The number of drums you're currently storing at your facility must also follow the rules lined out by this generator status.
State versus Federal OSHA Audit
Federal audits are less common than state audits. That's not to say federal inspections can't happen, but unless you are a very large company, you're much more likely to see a state audit. Regardless, whether you're a small auto body shop or a giant manufacturing facility, you and your employees should operate every day as if an inspector is going to walk in the door at any minute!
In general, you will have time to address and fix any violations found in either a state or federal audit, but if you have already been warned about an issue, you will enjoy less and less leeway and stricter and stricter penalties as offenses become repeat offenses.
Feeling Overwhelmed? Look into Hazardous waste Management Companies
If you're feeling daunted by all these rules you must know and follow in a landscape that changes frequently, look into your local hazardous waste removal companies. They can help you manage all your hazardous waste needs. Just make sure to do your research and find the right hazardous waste disposal company. If the company isn't entirely reputable and knowledgeable about the industry, your company could be the one paying the price when a surprise audit happens.
You rely on hazardous waste disposal companies to guide you in the right direction, and choosing poorly is never a valid excuse with the inspecting body.
For more information about hazardous waste audits and what to expect, please feel free to contact a representative of MCF Environmental Services, a waste management Atlanta company.
