Hazardous Waste Generator Inspection

Inspection template for hazardous waste accumulation areas to verify RCRA generator compliance, including labeling, dating, containment, storage limits, and the 90-day accumulation window.

Area Identification and General Condition

• Accumulation area is clearly designated and accessible only to authorized personnel
  Verify the hazardous waste accumulation area is identified, controlled, and not used for unrelated storage.
• Area is orderly, free of incompatible debris, and maintained in good housekeeping condition
  Check for spills, clutter, blocked access, or evidence of poor housekeeping that could affect safe storage.
• Aisles and access paths are unobstructed
  Verify personnel can safely access containers, emergency equipment, and exits without obstruction.
• Warning signs and hazard communication postings are visible where required
  Confirm required signage is posted and legible at the accumulation area entrance or point of storage.

Container Labeling and Dating

• Each container is labeled or marked as hazardous waste
  Verify every waste container is clearly identified as hazardous waste and not mistaken for product or non-waste material.
• Container contents are described with a proper waste description
  Check that the label identifies the waste stream or contents in a way that is understandable to employees and responders.
• Accumulation start date is present and legible on each container
  Verify the date waste first entered the container is marked and readable.
• Container date is within the allowed accumulation window
  Confirm the container has not exceeded the applicable generator accumulation limit, including the 90-day window where applicable.

Container Condition and Secondary Containment

• Containers are in good condition with no visible rust, bulging, cracks, or leaks
  Inspect each container for damage, corrosion, deformation, or evidence of release.
• Containers are closed except when adding or removing waste
  Verify lids, bungs, and closures are secured and containers are not left open.
• Containers are compatible with the stored waste
  Check that the container material is suitable for the waste and not showing signs of incompatibility or degradation.
• Secondary containment is present and free of accumulated liquid or residue
  Verify containment is provided where required and that it is maintained to prevent uncontrolled release.

Segregation, Storage Limits, and Compatibility

• Incompatible wastes are segregated to prevent mixing or reaction
  Check that acids, bases, oxidizers, flammables, toxics, and other incompatible wastes are separated as needed.
• Maximum allowed quantity is not exceeded for the accumulation area
  Verify the total amount of hazardous waste stored does not exceed site or regulatory storage limits for the generator category.
• Waste is stored in a manner that prevents tipping, falling, or damage during normal operations
  Confirm containers are stable, properly arranged, and protected from impact or movement.
• Flammable or reactive waste is stored away from ignition sources and heat
  Verify separation from heaters, sparks, open flames, and other ignition sources where applicable.

Emergency Preparedness and Documentation

• Spill response materials are available and appropriate for the waste stored
  Confirm absorbents, neutralizers, or other response supplies are present and suitable for the hazards in the area.
• Emergency equipment is accessible and unobstructed
  Verify fire extinguishers, eyewash stations, alarms, or other required emergency equipment can be reached quickly.
• Inspection records, manifests, or waste logs are available and current
  Check that required documentation supports waste identification, accumulation dates, and inspection history.
• Inspector notes corrective actions for any deficiency or non-conformance
  Document observed deficiencies, immediate controls, responsible party, and due date for correction.