Why you need to keep track of how much hazardous waste you generate in a month

If you are a small quantity generator (someone who generates between 100 and 1000 kg of hazardous waste per calendar month), you should make a point of keeping track of how much waste you generate in a month. The law does not require you to do that. But it is to your great benefit to do so. Why?

Just read the last paragraph of an actual Hazardous Waste Inspection Report from the Pennsylvannia Department of Protection.  Click here dep-inspection-form.

Here is the text in the inspection report reproduced here for your easy reading: “1832 lbs of hazardous waste was transported offsite on August 3, 2001 & 3143 lbs of hazardous waste was transported offsite on august 31, 2001. It is apparent that more than 2200 lbs of hazardous waste was generated in August of this year. Therefore the facility should follow the federal and state requirements for a LQG of hazardous waste.”

The facility was in fact a SQG. The inspector was wrong.

But in the absence of any documentation that showed the facility never generated more than 2200 lbs of waste in a calendar month, the inspector assumed incorrectly that the facility generated all the wastes that were shipped out in August of 2001 in that month. The reality was that the wastes in the two shipments made in August had been accumulated over the past several months.

If the facility had kept track of its waste generation, the inspector would not have made the wrong assumption. All you need is a piece of paper showing the date a 55-gallon waste container becomes full.



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