Both large and small hazardous waste generators are subject to the provisions of Part 265, Subpart C of RCRA – which calls for the generators to prepare for and prevent chemical accidents at the place where they store hazardous wastes. Subpart C requires the following:
- An alarm or communication system that is capable of providing emergency instructions to employees.
- A two-way communication system at the waste storage area.
- Fire fighting equipment such as fire extinguishers, water hose stations, automatic sprinklers and spill control and decontamination equipment.
- Regular testing of the equipment in 3 to ensure that they work.
- Adequate aisle space in the waste storage area to enable emergency personnel to get to the source of the emergency.
- Procedures that will minimize the possibility of fire, explosion or spills.
- Coordination with local authorities (fire department, police department and local hospitals) on how emergencies will be addressed.
It is very common for an inspector to find deficiencies in this area. Either you have a two-way telephone system or you don’t. Either you have adequate aisle space or you don’t. If your equipment is not working or in bad shape, the inspector will notice that too.
These are all low-hanging fruits for the inspectors. That’s why they are one of the most commonly cited RCRA violations.
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