Hazardous waste storage areas are among the most closely scrutinized areas during EPA and state environmental inspections. The Resource Conservation and Recovery Act (RCRA) under 40 CFR Parts 262 and 265 requires generators to properly manage, label, contain, and inspect hazardous waste containers throughout the accumulation period. Weekly inspections of storage areas are mandatory for large and small quantity generators. Violations related to container management, labeling, accumulation time limits, and secondary containment consistently rank among the most common RCRA enforcement actions. This guide covers all inspection requirements with a free downloadable checklist.
Free Hazardous Waste Storage Inspection Checklist
Download our Word document checklist covering container condition, labeling, dating, secondary containment, and accumulation time limits per RCRA.
Download Checklist (.docx)Regulatory Framework
RCRA Generator Requirements — 40 CFR Part 262
- 262.17 (LQG): Large quantity generators may accumulate hazardous waste up to 90 days without a storage permit, provided all conditions are met including weekly inspections, proper labeling, container management, and emergency preparedness.
- 262.16 (SQG): Small quantity generators may accumulate up to 270 days (or 180 days if not transporting over 200 miles). Weekly inspections required. Maximum quantity on site: 6,000 kg.
- 262.14 (VSQG): Very small quantity generators may accumulate up to 1,000 kg. No federal weekly inspection requirement, but best practice to inspect regularly.
- 262.15: Satellite accumulation allows up to 55 gallons (or 1 quart acutely hazardous) at or near the point of generation under control of the operator. When full, must be dated and moved within 3 days.
Container Management Standards — 40 CFR 265 Subpart I
- 265.171: Container must be in good condition. If deteriorating, waste must be transferred to a container in good condition.
- 265.172: Container must be compatible with the waste stored in it.
- 265.173: Containers must be kept closed during storage except when adding or removing waste.
- 265.176: Minimum 15-meter (50-foot) separation between ignitable or reactive waste containers and the facility property line.
- 265.177: Incompatible wastes must not be placed in the same container or in unwashed containers that held incompatible materials.
Time limit enforcement: Exceeding the 90-day (LQG) or 270/180-day (SQG) accumulation time limit means the generator is operating a storage facility without a RCRA permit, potentially triggering full Part 264/265 storage facility requirements, permit obligations, and significant penalties.
Part 1: Container Condition & Management
| Inspection Item | What to Check |
|---|---|
| Container condition (weekly) | All containers in good condition per 265.171. No leaks, rust, dents, bulging, or structural damage. No staining or discoloration on exterior indicating leakage. Deteriorating containers must have waste transferred to sound containers immediately. |
| Containers closed (weekly) | All containers kept closed during storage per 265.173. Lids, bungs, caps, and closure devices properly secured. No open containers except when actively adding or removing waste. Funnel lids (if used) must be self-closing. |
| Compatibility | Container material compatible with waste per 265.172. No reactive, incompatible wastes in same container per 265.177. Incompatible wastes separated by dike, berm, wall, or other device. No incompatible materials stored in adjacent, unwashed containers. |
| Container handling | Containers not stacked unless structurally sound and safe to do so. Adequate aisle space for inspection, sampling, and emergency equipment access (typically minimum 30 inches). Containers on pallets or raised surfaces where flooding is a concern. |
| Ignitable/reactive waste | Ignitable or reactive waste containers stored at least 15 meters (50 feet) from the facility property line per 265.176. “No Smoking” signs posted. Protected from sources of ignition. Grounding and bonding in place for flammable liquid transfers. |
Part 2: Labeling, Marking & Dating
| Inspection Item | What to Check |
|---|---|
| “Hazardous Waste” marking | Each container clearly marked with the words “Hazardous Waste” per 262.17(a)(1)(iv)/262.16(b)(6). Marking legible, visible, and not obscured by dirt, damage, or stacking. Label visible from aisle side of container. |
| Accumulation start date | Date when waste first placed in container clearly marked on each container. Date legible and accurate. Containers within applicable time limits (90 days LQG, 180/270 days SQG). No undated containers in central accumulation area. |
| Hazard indication | Containers labeled with an indication of the hazards of the contents using DOT placards/labels, GHS hazard labels, or EPA hazardous waste characteristic labels (ignitable, corrosive, reactive, toxic). Hazard communication consistent and clear. |
| Waste stream identification | Contents of each container identifiable. Waste codes (EPA and state) documented. Waste profile sheet or waste determination on file. No containers with unknown contents. Waste characterization records maintained for at least 3 years. |
| Satellite area marking | Satellite accumulation containers marked “Hazardous Waste” with an indication of contents per 262.15. Container at or near the point of generation and under control of the operator. Volume not exceeding 55 gallons (or 1 quart acutely hazardous). |
Part 3: Storage Area & Containment
| Inspection Item | What to Check |
|---|---|
| Secondary containment | Containment system in place and in good condition (berms, dikes, or curbed areas). Capacity sufficient to hold at least 10% of total container volume or volume of largest container (whichever greater, per state requirements). No cracks, gaps, or deterioration in containment structure. |
| Containment maintenance | Containment area free of standing liquids (unless from a leak requiring response). Drain valves closed and locked when not in active use. Containment not used for non-waste storage purposes. Accumulated rainwater managed properly. |
| Storage area condition | Base and floor impervious and free from cracks. No staining indicating past releases. Area well-ventilated if storing volatile wastes. Adequate lighting for inspections. Weather protection (cover/roof) where required. |
| Emergency equipment | Fire extinguisher appropriate for waste types, inspected, and accessible. Spill cleanup materials (absorbents, overpack drums, PPE) readily available. Eye wash/safety shower accessible within required distance if handling corrosives. Emergency contact information posted. |
| Security | Storage area secured to prevent unauthorized access. Fencing, locked gates, or building access controls in place. “Danger — Hazardous Waste Storage Area” or equivalent signage posted. Access limited to trained and authorized personnel. |
| Emergency preparedness | Emergency coordinator designated. Contingency plan current and posted or accessible. Emergency equipment operable. Arrangements with local emergency responders documented. Communication equipment (phone, radio) accessible. |
Generator category summary: Large Quantity Generator (LQG): generates 1,000+ kg/month, 90-day accumulation limit, weekly inspections required per 262.17. Small Quantity Generator (SQG): generates 100–1,000 kg/month, 180/270-day limit, 6,000 kg maximum on site, weekly inspections required per 262.16. Very Small Quantity Generator (VSQG): generates under 100 kg/month, 1,000 kg maximum on site, no federal weekly inspection requirement. State requirements may be more stringent than federal RCRA — always verify with your state hazardous waste program.
Download the Free Checklist
Get our hazardous waste storage inspection checklist in Word format. Covers all RCRA container management requirements.
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Weekly hazardous waste storage area checklists with photo documentation and deficiency tracking.
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