Hazardous waste self-audit checklist - Very Small Quantity ...



Hazardous waste self-audit checklistVery Small Quantity GeneratorsEnvironmental Audit & Hazardous Waste Compliance ProgramsDoc Type: Environmental AuditsPurpose: Self-audit checklists provide businesses with an easy way to review compliance with Minnesota’s environmental laws and rules. However, because how the hazardous waste regulations apply to specific situations can be complex, your site may have additional requirements that are not covered on this checklist.The Minnesota Pollution Control Agency (MPCA) administers the Minnesota Rules that regulate hazardous waste in Minnesota. These Rules are more stringent than the parallel federal regulations. In the Metropolitan Counties of Anoka, Carver, Dakota, Hennepin, Ramsey, Scott, and Washington (Metro Counties), county ordinances may also mandate additional requirements.Questions: If you have questions about this checklist or the hazardous waste requirements, contact the MPCA or your Metro County hazardous waste staff. See More information on page 7; or for free, confidential guidance, contact the MPCA’s Small Business Environmental Assistance Program at smallbizhelp.pca@state.mn.us or by telephone at 651-282-6143.For more information: The MPCA’s hazardous waste fact sheets can be found on the MPCA’s website at this the right checklist for the site?Use the checklist appropriate for the site’s hazardous waste generator size. A site’s generator size depends on the volume and type of hazardous waste generated at the site each calendar month and year, and determines the hazardous waste requirements applicable to the site. For help calculating a site’s size, see MPCA fact sheet #w-hw1-02, Determine generator size, at: waste self-audit checklists:Very Small Quantity Generator (VSQG)#ea-g1-32 Quantity Generator (SQG)#ea-g1-33 Quantity Generator (LQG)#ea-g1-34 to use this checklistTo assist generators to learn and apply the hazardous waste requirements, the MPCA has divided them in to ten areas, referred to as the 10+ Steps to hazardous waste compliance. You may find a summary of the 10+ Steps to hazardous waste compliance, and links to more detailed guidance for each Step, in MPCA fact sheet #w-hw1-00, Summary of hazardous waste requirements, at: checklist will ask you a series of questions for each Step. Click on a square to mark ‘Yes’ or ‘No’.If the answer is “Yes,” the site is likely in compliance with the Minnesota hazardous waste requirements.If the answer is “No,” the site is likely noncompliant and changes need to be made.If you are unsure, review the linked guidance information or contact the MPCA See More information on page 7.Step 1. Evaluate the site’s wastesMPCA fact sheet #w-hw1-01, Evaluate waste, at: all the wastes generated at the site. Include wastes that are: shipped off-site, thrown into the solid waste (trash), sewered, recycled on-site, treated on-site, or deliberately evaporated. FORMTEXT ?????1-2.Has each of the above-listed wastes been evaluated, or in the alternative, assumed to be hazardous? FORMCHECKBOX Yes FORMCHECKBOX No1-3.Are all references, analyses, or other documentation used to evaluate each waste accessible from the site? FORMCHECKBOX Yes FORMCHECKBOX No1-4.If unwanted materials, products, or inventory are shipped off-site for reuse or resale, is the material managed legitimately as a product to ensure it does not need to be managed as a waste?See MPCA fact sheet #w-hw3-36a, Reverse logistics of unwanted materials, at: . FORMCHECKBOX Yes FORMCHECKBOX N/A – Unwanted materials are not shipped off-site. FORMCHECKBOX NoStep 2. Determine or recheck the site’s generator sizeMPCA fact sheet #w-hw1-02, Determine generator size, at: the site’s generator size rechecked each month when the volume of business changes, inventory is cleaned out, or a process is started or shut down? FORMCHECKBOX Yes FORMCHECKBOX NoStep 3. Obtain and maintain the site’s hazardous waste identification number (HWID)MPCA fact sheet #w-hw1-03, Obtain an HWID, at: the site have an active HWID, also known as an EPA ID Number, assigned to the current generator?Search for the site’s HWID and check whether it is active using the MPCA’s What’s in my neighborhood tool at: FORMCHECKBOX Yes FORMCHECKBOX NoRequest an HWID using the MPCA’s e-Services portal. Find instructions to use e-Services in MPCA fact sheet #w-hw5-12, Notification of regulated waste activity, at: part of this audit, has an updated Notification of regulated waste activity with the current site contact staff, telephone, and email address been submitted to the MPCA using e-Services?Follow the instructions in Section D, Modify an existing HWID, of MPCA fact sheet #w-hw5-12 linked above. FORMCHECKBOX Yes FORMCHECKBOX NoStep 4. Hazardous waste licensingMPCA Hazardous waste licensing webpage, at: the site have a current generator license from the MPCA or your Metro County?Non-Metro County generators may access their hazardous waste licenses and print a copy at:. Metro County generators must contact their County (see page 7). FORMCHECKBOX Yes FORMCHECKBOX No4-2.Is the site’s license posted in a public area at the site?Employee-only areas, such as lunch or break rooms, ‘communication boards’, or legal notice posting areas are not considered public and do not meet this requirement. FORMCHECKBOX Yes FORMCHECKBOX NoStep 5. Accumulating hazardous waste safelyMPCA fact sheet #w-hw1-05, Accumulate hazardous waste, at: all hazardous waste containers compatible with the waste stored in them?Make sure that the containers will not absorb, react with, or be affected by the contents. FORMCHECKBOX Yes FORMCHECKBOX No5-2.Are all hazardous waste containers in good condition, leakproof, and sturdy?Containers must be sturdy enough to contain the waste even if subjected to reasonably likely mishandling or impact when full. Containers must not be damaged, corroded, or missing necessary parts. FORMCHECKBOX Yes FORMCHECKBOX No5-3.Are all hazardous waste containers closed except when waste is actually being added/removed?Closed means that no waste would be released from the container if overturned. Lids held on by gravity are insufficient. Snap or bolt rings must be secured, funnels physically attached and lidded or valved, and bungs screwed in tight. FORMCHECKBOX Yes FORMCHECKBOX No5-4.Are all hazardous waste containers legibly labeled with the words ‘Hazardous waste’? FORMCHECKBOX Yes FORMCHECKBOX No5-5.Are all hazardous waste containers legibly labeled with a clear description of the waste? FORMCHECKBOX Yes FORMCHECKBOX No5-6.Are hazardous waste standard accumulation containers legibly labeled with the accumulation start date?Standard accumulation containers are generally those in which waste will be directly shipped when full, that will not be emptied into another container, or that are no longer eligible to be satellite accumulation containers. The accumulation start date is the day that waste was first added to a standard accumulation container, or the date a satellite accumulation container became regulated as a standard accumulation container. FORMCHECKBOX Yes FORMCHECKBOX No5-7.Are all hazardous waste containers holding liquid placed onto an impermeable containment surface?A containment surface must be able to contain the full contents of the container without the waste reaching the outdoor environment through open floor, storm, or sanitary sewer drains, cracks, doors, or other openings. You may use distance from exterior doors to meet the containment surface requirement, or may use spill pallets or curbed locations. FORMCHECKBOX Yes FORMCHECKBOX No5-8.Are all hazardous waste containers segregated from nearby incompatible materials?Containers holding hazardous wastes incompatible with other materials nearby must be segregated by physical structures or distance, so that if both materials leaked, they could not come into contact with each other. FORMCHECKBOX Yes FORMCHECKBOX No5-9.Are all hazardous waste containers protected from inadvertent damage from vehicles and equipment? FORMCHECKBOX Yes FORMCHECKBOX No5-10.Are any hazardous waste containers of ignitable or reactive wastes at least 50 feet from the site’s property line? FORMCHECKBOX Yes FORMCHECKBOX No5-11.Do you have enough aisle space around all hazardous waste containers to be able to move any hazardous waste container out of its current location without moving any other hazardous waste containers or equipment? FORMCHECKBOX Yes FORMCHECKBOX No5-12.If hazardous waste is accumulated outside, are the containers secured to prevent unauthorized access? FORMCHECKBOX Yes FORMCHECKBOX N/A – Hazardous waste is not accumulated outside at this site. FORMCHECKBOX No5-13.If hazardous waste is accumulated outside, are containers holding liquid in a completely curbed area? FORMCHECKBOX Yes FORMCHECKBOX N/A – Hazardous waste is not accumulated outside at this site. FORMCHECKBOX No5-14.If hazardous waste is accumulated outside, are any containers holding ignitable or reactive wastes protected from sun and precipitation exposure? FORMCHECKBOX Yes FORMCHECKBOX N/A – Hazardous waste is not accumulated outside at this site. FORMCHECKBOX No5-15.Does the site ensure that no more than 2200 pounds (approximately four 55-gallon drums) of hazardous waste are accumulated on-site at any time (not including hazardous waste in satellite accumulation containers)? FORMCHECKBOX Yes FORMCHECKBOX No5-16.Do all hazardous waste satellite accumulation areas hold less than 55 gallons of each waste stream? FORMCHECKBOX Yes FORMCHECKBOX No5-17.Are inspections of all hazardous waste standard accumulation containers to ensure compliance with Questions 5-1 through 5-16 performed every calendar week and documented? FORMCHECKBOX Yes FORMCHECKBOX NoStep 6. Properly treat or dispose of hazardous wasteMPCA fact sheet #w-hw1-06, Treat or dispose of hazardous waste, at: any hazardous waste is treated on-site in open containers or tanks, such as by mixing two-part epoxies or evaporating aqueous waste, has the treatment process been approved by the MPCA or Metro County? FORMCHECKBOX Yes FORMCHECKBOX N/A – Hazardous waste is not treated on-site. FORMCHECKBOX No6-2.If any hazardous waste is discharged to the sanitary sewer, has the publicly owned treatment works (POTW, also known as the sewage treatment plant) been notified and any conditions they apply complied with? FORMCHECKBOX Yes FORMCHECKBOX N/A – Hazardous waste is not discharged to the sanitary sewer. FORMCHECKBOX No6-3.If any hazardous waste is disposed by mixture into used oil on-site, is a record prepared for each mixing event showing that a maximum 1:10 mixture ratio is not exceeded? FORMCHECKBOX Yes FORMCHECKBOX N/A – Hazardous waste is not mixed into used oil for disposal. FORMCHECKBOX No6-4.Is at least one employee on-site trained in the U.S. Department of Transportation (DOT) Hazardous Materials Regulations (HMR) characterization, packaging, and marking requirements? FORMCHECKBOX Yes FORMCHECKBOX No6-5.Is all hazardous waste transported off-site, whether by commercial transporter or in the business’ own vehicles, packaged and marked in compliance with the HMR? FORMCHECKBOX Yes FORMCHECKBOX No6-6.Are all used product and waste containers checked before disposal or recycling to ensure that the containers meet the hazardous waste standard for an exempt empty container?For an explanation of the empty container standard, see MPCA fact sheet #w-hw4-16, Containers that held hazardous wastes or products, at: . FORMCHECKBOX Yes FORMCHECKBOX NoStep 7. Documenting shipments of hazardous wasteMPCA fact sheet #w-hw1-07, Manifest shipments, at: any hazardous waste is shipped off-site by commercial transporter, has a site employee registered with the U.S. Environmental Protection Agency’s (EPA) eManifest System to access and view the site’s manifests? FORMCHECKBOX Yes FORMCHECKBOX N/A – Hazardous waste is not shipped using a commercial transporter. FORMCHECKBOX No7-2.If any hazardous waste is shipped off-site by commercial transporter, does a site employee trained in the HMR check the uniform hazardous waste manifest for accuracy before the transporter leaves the site? FORMCHECKBOX Yes FORMCHECKBOX N/A – Hazardous waste is not shipped using a commercial transporter. FORMCHECKBOX No7-3.If any hazardous waste is transported by the business to a VSQG Collection Program, is a receipt for the waste obtained from the Collection Program and retained for at least three years from the shipment date? FORMCHECKBOX Yes FORMCHECKBOX N/A – Hazardous waste is not transported to a Collection Program. FORMCHECKBOX NoStep 8. Planning for emergenciesMPCA fact sheet #w-hw1-08a, Emergency planning for VSQGs, at: there a reliable method to provide emergency instructions to employees on site? FORMCHECKBOX Yes FORMCHECKBOX No8-2.Do all employees handling hazardous waste have immediate access to emergency communications in their work area or on their person?Employees must be provided a reliable method to immediately summon aid without leaving the location where hazardous waste is being handled. FORMCHECKBOX Yes FORMCHECKBOX No8-3.Are portable fire extinguishers located in all areas where hazardous waste is handled? FORMCHECKBOX Yes FORMCHECKBOX No8-4.Are all portable fire extinguishers in hazardous waste handling areas checked by site employees at least monthly and maintained by trained technicians at least annually?Annual fire extinguisher maintenance must be physically documented on extinguishers with a tag, collar, or sticker. FORMCHECKBOX Yes FORMCHECKBOX No8-5.Is spill control equipment appropriate to the waste in type and amount located and maintained in each area where hazardous waste is handled? FORMCHECKBOX Yes FORMCHECKBOX No8-6.Is employee decontamination equipment appropriate to the waste in type and capacity located and maintained in each area where hazardous waste is handled? FORMCHECKBOX Yes FORMCHECKBOX NoStep 9. Employee trainingMPCA fact sheet #w-hw1-09a, Employee training for VSQGs, at: training is not mandated for VSQGs in Minnesota; however, the MPCA strongly recommends that employees handling hazardous waste be trained in any of the questions in this checklist relevant to their duties.Step 10. RecordkeepingMPCA fact sheet #w-hw1-10, Keep hazardous waste records, at: all documentation used to evaluate wastes as non-hazardous retained for at least three years after the site last generates the waste? FORMCHECKBOX Yes FORMCHECKBOX No10-2.Are VSQG Collection Program receipts (see Question 7-3 on this page), used oil shipment records (see Question +-10 on page 6), hazardous waste/used oil mixture records, if applicable (see Question 6-3 on page 4), and weekly hazardous waste container inspection records (see Question 5-17 on page 4) retained for at least three years from the date of the record? FORMCHECKBOX Yes FORMCHECKBOX NoStep +. Universal wastes, used oil, E-waste, and pharmaceutical wastesMPCA fact sheet #w-hw4-62, Universal wastes, at: fact sheet #w-hw4-30, Used oil and related wastes, at: fact sheet #w-hw4-15, Electronic wastes, at: fact sheet #w-hw3-33, Pharmaceutical waste management, at: either all containers of universal waste, or each item of universal waste, labeled with the phrase ‘Universal waste [type]’, ‘[Type] waste’, or ‘Used [type]’? FORMCHECKBOX Yes FORMCHECKBOX No+-2.Can the site demonstrate that universal waste is accumulated on the site for less than one year? FORMCHECKBOX Yes FORMCHECKBOX No+-3.Is all damaged universal waste placed into a compatible, closed container?Broken fluorescent lamps must be placed into airtight containers, made of or lined with plastic. FORMCHECKBOX Yes FORMCHECKBOX No+-4.Are all used oil and related wastes, including used floor dry and oily rags, managed by recycling or by burning for energy recovery in an on-site space heater or off-site industrial furnace? FORMCHECKBOX Yes FORMCHECKBOX No+-5.Are all used oil and related wastes, including used oil filters, stored in closed, leakproof, containers?Closed means that no oil would be released from the container if overturned. Lids held on by gravity are insufficient. Snap or bolt rings must be secured, funnels physically attached and lidded or valved, and bungs screwed in tight. FORMCHECKBOX Yes FORMCHECKBOX No+-6.Are all containers of used oil and related wastes labeled with the phrase ‘Used Oil [type]’? FORMCHECKBOX Yes FORMCHECKBOX No+-7.Are all containers of used oil located on concrete, metal, or plastic?Used oil containers may not be located on asphalt, dirt, gravel, or soil. FORMCHECKBOX Yes FORMCHECKBOX No+-8.If used oil generated on the site, or that is collected from do-it-yourselfers, is burned on-site, is it burned in a space heater that is designed to burn used oil, vented to the outside, and is compliant with the State Fire Code? FORMCHECKBOX Yes FORMCHECKBOX N/A – Used oil is not burned on-site. FORMCHECKBOX No+-9.If used oil is shipped off-site for burning, is it either burned only in an industrial furnace or tested and shown to meet used oil specifications before being burned in any other device? FORMCHECKBOX Yes FORMCHECKBOX N/A – Used oil is not shipped off-site for burning. FORMCHECKBOX No+-10.Is a record of every off-site shipment of used oil and related wastes prepared? FORMCHECKBOX Yes FORMCHECKBOX No+-11.Are records kept to show that at least 75% of the weight of E-waste generated at the site every year is recycled or shipped off-site for recycling? FORMCHECKBOX Yes FORMCHECKBOX No+-12.Has the site stopped any sewering of federally-regulated or unevaluated pharmaceutical wastes? FORMCHECKBOX Yes FORMCHECKBOX NoCertificationI certify under penalty of law that I have personally examined and am familiar with the information contained in this and any attached documents, and that based on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the submitted information is true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment.By typing/signing my name below, I certify the above statements to be true and correct, to the best of my knowledge, and that this information can be used for the purpose of processing this form.Authorized RepresentativeSignature: FORMTEXT ?????Title: FORMTEXT ?????(This document has been electronically signed.)Date (mm/dd/yyyy): FORMTEXT ?????What do I do after completing this checklist?If you completed this checklist voluntarily only for your site’s own use, the MPCA encourages you to follow up on any questions marked ‘No’ to bring the site’s hazardous waste operations back into compliance with Minnesota requirements.MPCA Environmental Audit ProgramSites voluntarily completing this checklist may also apply to participate in the MPCA’s Environmental Audit Program (EAP). Sites performing a self-audit on their own initiative, reporting found deficiencies to the MPCA, and correcting all noncompliance may be eligible for protection from MPCA enforcement actions, including potential penalties that might otherwise be assessed for the violations, if certain conditions are met. Sites meeting the requirements of the EAP may also be eligible to be publicly designated a Green Star Facility. For more information on the EAP, visit the MPCA Environmental audit program webpage at: Compliance and Enforcement Section or Metro County StaffSome sites may also be directed to complete this checklist by MPCA Compliance and Enforcement Section or Metro County staff in lieu of an on-site inspection by MPCA or Metro County inspector staff, for reasons of public safety or health.If your site is instructed to complete this checklist, complete the entire checklist at one time; do not leave questions blank until you resolve found violations if you would have marked ‘No’, indicating noncompliance, when initially completing the checklist. Attach a short summary of any violations found along with your plan for correcting them, and return these along with the completed checklist to the MPCA or Metro County inspector staff.More informationGuidance and requirements in this checklist were compiled from Minn. R. ch. 7045. Visit the Office of the Revisor of Statutes’ website at to review Minnesota Rules.Contact your Metro County or the MPCA with your questions. The MPCA’s Small Business Environmental Assistance Program can also provide free, confidential regulatory compliance assistance. The Minnesota Technical Assistance Program (MnTAP) can help you reduce the amount of hazardous waste your site generates.Metro County Hazardous Waste OfficesAnoka763-324-4260 952-496-8177 Pollution Control AgencyToll free (all offices)1-800-657-3864All offices651-296-6300 Business Environmental AssistanceToll free 1-800-657-3938Metro 651-282-6143 Technical Assistance ProgramToll free 1-800-247-0015Metro 612-624-1300 ................
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