Waste management audit checklist
Version 1 · https://conformata.io/checklists/environment/waste-management-audit · Made with Conformata. Guidance, not legal advice; sources at https://conformata.io/checklists/environment/waste-management-audit/sources
Waste management audit checklist
Free waste management audit checklist for US sites under the EPA RCRA generator rules: accumulation areas, labels, weekly inspections, manifests, records.
How often: Audit frequency is set by your organization. Small and large quantity generators inspect their central accumulation areas at least weekly.
- Sections
- 9
- Checks
- 54
- Critical
- 0
- Sources
- 77
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Site name and address *
Date of audit *
Name of the person doing the audit *
Generator category the site has determined for this calendar month *
Very small quantity generator (VSQG)Small quantity generator (SQG)Large quantity generator (LQG)Not yet determined for this month
EPA identification number
Every waste stream on site has a hazardous waste determination made at its point of generation *
YesNo
Records support each hazardous waste determination (test results, process knowledge or other information used) *
YesNoN/A
The generator category was worked out for the current calendar month from the amount of hazardous waste generated *
YesNo
Very small quantity generators: non-acute hazardous waste accumulated on site is below 1,000 kg (2,200 lb) *
YesNoN/A
Containers at or near the point where waste is first collected. Mark N/A for very small quantity generators.
Satellite containers are at or near the point where the waste is generated and under the control of the operator of that process *
YesNoN/A
No satellite area holds more than 55 gallons of non-acute hazardous waste, 1 quart of liquid acute hazardous waste or 1 kg (2.2 lb) of solid acute hazardous waste *
YesNoN/A
Any container holding waste over the satellite limit is marked with the date the excess began and is moved within three consecutive calendar days
YesNoN/A
Satellite containers are closed except while waste is being added, removed or consolidated *
YesNoN/A
Satellite containers are in good condition and not leaking *
YesNoN/A
Each container is made of or lined with material that does not react with the waste inside *
YesNoN/A
Incompatible wastes have been put in the same container *
YesNoN/A
Each satellite container is marked with the words "Hazardous Waste" *
YesNoN/A
Each satellite container shows the hazards of its contents (for example ignitable or corrosive, a DOT hazard label, or an OSHA pictogram) *
YesNoN/A
Small and large quantity generators only. Mark N/A for very small quantity generators.
No container has been in the central accumulation area longer than the limit for the site's category (180 days small quantity, 90 days large quantity) *
YesNoN/A
Each container shows the date accumulation began, clearly visible *
YesNoN/A
Each container is marked with the words "Hazardous Waste" *
YesNoN/A
Each container shows the hazards of its contents *
YesNoN/A
Containers are closed except when waste is being added or removed *
YesNoN/A
No container is leaking or showing corrosion or other deterioration *
YesNoN/A
The central accumulation area has been inspected at least weekly since the last audit *
YesNoN/A
Containers of incompatible waste are separated or protected by a dike, berm, wall or other device
YesNoN/A
Small quantity generators: non-acute hazardous waste on site has never exceeded 6,000 kg (13,200 lb)
YesNoN/A
Large quantity generators: containers of ignitable or reactive waste are at least 15 m (50 ft) from the property line, or written approval from the local fire code authority is on file
YesNoN/A
Photo of the central accumulation area
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An internal alarm or communication system can give immediate emergency instructions to people where waste is generated or accumulated *
YesNoN/A
Fire extinguishers, spill control equipment and decontamination equipment are available where waste is generated or accumulated *
YesNoN/A
Aisle space lets people, fire protection, spill control and decontamination equipment reach every part of the waste area *
YesNoN/A
An emergency coordinator is on the premises or on call at all times *
YesNoN/A
Small quantity generators: next to the phone or in the waste area, a notice gives the emergency coordinator's name and number, where the fire extinguishers and spill material are, and the fire department number
YesNoN/A
Small quantity generators: employees know the waste handling and emergency procedures for their jobs
YesNoN/A
Large quantity generators: training records are kept at the facility and show each waste-handling employee has completed the annual review
YesNoN/A
The site has an EPA identification number before it stores, ships or offers hazardous waste for transport *
YesNoN/A
Each off-site shipment of hazardous waste left with a manifest (EPA Form 8700-22) *
YesNoN/A
Each manifest names a designated facility permitted to handle the waste *
YesNoN/A
Containers were marked with all applicable EPA hazardous waste codes before shipping
YesNoN/A
The site is registered in EPA's e-Manifest system to get signed copies of completed manifests
YesNoN/A
A copy signed by the receiving facility is on file for each manifest and kept at least three years from when the transporter accepted the waste *
YesNoN/A
For any shipment without a signed return copy, follow-up is on file (large quantity generators by day 45; small quantity generators by day 60)
YesNoN/A
Very small quantity generators: waste is treated or disposed of on site or delivered only to a type of facility the rule lists
YesNoN/A
Only for waste your organization manages as universal waste. Mark N/A when none is on site.
Waste batteries, or their container, are labeled "Universal Waste-Battery(ies)", "Waste Battery(ies)" or "Used Battery(ies)"
YesNoN/A
Any leaking or damaged battery is in a closed, compatible container
YesNoN/A
Waste lamps, or their container, are labeled "Universal Waste-Lamp(s)", "Waste Lamp(s)" or "Used Lamp(s)"
YesNoN/A
Lamps are in closed, structurally sound containers that prevent breakage
YesNoN/A
No universal waste has been kept longer than one year, and the site can show how long each item has been accumulated
YesNoN/A
Employees who handle universal waste have been told the handling and emergency procedures for it
YesNoN/A
Findings and corrective actions
Person responsible for corrective actions
Date corrective actions are due
Auditor's signature
Sign the printed copy, or sign electronically in Conformata.
I audited the hazardous waste areas and records of this site on the date recorded above.
Signature
Name and date
Run it with your team in Conformata
- Schedule it per site and assign it to the right people.
- Turn every failed check into a corrective action that someone else verifies.
- Keep signatures, photos and the full audit history across sites.
Answers on this page stay on this device; they are not transferred.
Frequently asked questions
What are the hazardous waste generator categories?
They depend on how much hazardous waste a site generates in a calendar month. A very small quantity generator generates no more than 100 kg (220 lb) of non-acute hazardous waste [6] [7]; a small quantity generator more than 100 kg but less than 1,000 kg (2,200 lb) [5]; and a large quantity generator 1,000 kg or more [1]. Generating more than 1 kg (2.2 lb) of acute hazardous waste in a month also makes a site a large quantity generator [2], as does generating more than 100 kg (220 lb) of residue, soil, water or other debris from cleaning up a spill of acute hazardous waste [3] [4]. Your organization makes this determination; the checklist does not.
How often must a hazardous waste storage area be inspected?
What must a hazardous waste container label say?
In satellite and central accumulation areas, containers are marked with the words "Hazardous Waste" and an indication of the hazards of the contents [25] [26]. In a central accumulation area the date accumulation began must also be clearly visible on each container [56]. Before shipping, containers are also marked with the applicable EPA hazardous waste codes [11].
How long do we keep manifests?
Built from 77 official sources
Every check traces to the text it is based on. Read the purpose, how to use it, the rules behind it, what it does not cover and every source.
Guidance, not legal advice. It does not replace the law, the manufacturer's instructions or your organization's competent people, and completing it does not certify that work is safe.