Things you should do even when they are not required by law

There are several things in the environmental world you should do even though they are not  required by law. They fall into the category of “good management practices”.

If you are a hazardous waste generator, you are required by law to inspect your central waste storage area weekly. However, you will not find any regulations that specifically require you to document the weekly inspections. As a good management practice, you should always keep a written log of your weekly inspections. This serves two purposes. One, it keep your staff vigilant in making sure the storage area is clean and the containers are in good condition. Second, it gives you a way to show the inspector that you are actually doing the weekly inspections.

If you are a small quantity generator (you generate less than 1000 kilograms of hazardous waste in a calendar month), you are required by law to have an emergency response plan. However, the regulations do not say that you have to have a “written plan”. If you have such a plan, you might as well have it in writing.

Another thing you should alway do as a SQG. You should alway keep track of how much wastes you are generating on an on-going basis. Why? That’s the only way you can demonstrate to an inspector that you are a small quantity generator. Read my earlier post on this subject.


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