Retail Initial Discussion Topic - Inspection Process

The hazardous waste inspector arrives at the store unannounced and informs the staff that they would like to conduct a hazardous waste inspection. The inspector asks to talk with the store manager or whoever is responsible for environmental compliance and/or safety that day.  Inspections are not announced to ensure that the observations made at the time of inspection are representative of the typical day to day store operations.

The hazardous waste inspector meets with the store representative and provides a brief overview of the inspection process.  An inspection typically includes a pre-inspection meeting to review required records, a store walk through to observe site specific waste management activities, and a post-inspection meeting to discuss any preliminary conclusions regarding compliance. 

During the record review, the hazardous waste inspector requests to review all paperwork required under the regulations. This includes paperwork associated with the handling, storing and disposing of hazardous waste, liquid industrial by-product and universal waste. Examples of required records include:

• Waste characterization records and waste inventory records used to verify a site’s hazardous waste  generator status
• Hazardous waste manifests and liquid industrial by-product shipping documents
• Emergency signage and emergency response equipment for small quantity and large quantity generators of hazardous waste
• Land disposal restrictions notifications for small quantity and large quantity generators of hazardous waste
• Training records, contingency plan and biennial reports for large quantity generators of hazardous waste
• Emergency response plans

During the store walk through, the hazardous waste inspector performs a visual inspection of the whole facility, and looks closely at area(s) where the hazardous waste, universal waste, and liquid industrial by-products are generated, accumulated, and shipped for disposal.  The inspector is making observations as to whether the waste is managed to meet the regulatory requirements intended to protect human health and the environment.  The inspector is reviewing site conditions to answer questions that will verify compliance like:

• Are containers closed except when adding or removing waste
• Are containers protected from weather, fire, physical damage, and vandals
• Are containers properly labeled to meet the liquid industrial by-products, hazardous waste, and/or universal waste regulations
• Are there more wastes than what was characterized
• Are containers labeled with:
  • an accumulation date, the words hazardous waste, and the applicable hazardous waste code(s);
  • an accumulation date, the words universal waste and the type of waste (pharmaceutical, electric lamps, etc.)
  • a description of the liquid industrial by-product (e.g. used oil or waste antifreeze)
• Does the store have adequate emergency response and communication equipment to address the hazards associated with the type of waste generated
• Is there adequate aisle space for emergency responders to address a spill or fire
• Are container labels visible at all times
• Are incompatible materials accumulated separately, protected from each other by physical barriers or sufficient distance
• Are wastes shipped off as frequently as required (e.g. at least every 90 days for large quantity generators, every 180 days for small quantity generators, and annually for universal wastes)

The inspector will also ask questions about waste handling practices as well as emergency response plans and equipment.  These questions are asked to ensure adequate measures are in place, and adequate training has been provided, to meet the waste management requirements and know what to do in the event of an emergency. 

Finally the inspector will complete the inspection with a brief meeting, sharing any preliminary compliance findings, and noting any issues and recommendations.  Once back at the office, the inspector will review copies of records more closely to determine if compliance is achieved.  This may include review of waste transporters and receiving facilities; to verify they have the required authorizations to accept the waste offered for transport, treatment, storage, and/or disposal.