The Resource Conservation and Recovery Act (RCRA) establishes a comprehensive framework for managing hazardous waste from generation through disposal. While routine inspections check container conditions and labeling, a program audit evaluates whether your entire hazardous waste management program meets RCRA requirements including correct generator status determination, proper waste characterization, compliant accumulation practices, accurate manifesting, and adequate personnel training. EPA and state inspectors conduct unannounced compliance evaluations, making regular self-audits essential for identifying and correcting issues before they become violations.
Free RCRA Hazardous Waste Program Audit Checklist
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Download Checklist (.docx)Regulatory Requirements
RCRA 40 CFR 262 — Generator Requirements
Generators of hazardous waste must determine their generator status (Very Small Quantity Generator, Small Quantity Generator, or Large Quantity Generator) based on the amount of hazardous waste generated per calendar month. Each category has different requirements for accumulation time limits, container management, training, emergency preparedness, and reporting.
RCRA 40 CFR 265 — Interim Status Standards
Facilities that store, treat, or dispose of hazardous waste must comply with interim status standards covering container management, tank systems, containment buildings, and more. Even generators accumulating waste on-site must follow applicable container management standards.
Land Disposal Restrictions (LDR) — 40 CFR 268
Hazardous waste must meet treatment standards before land disposal. Generators must determine applicable treatment standards and provide proper notifications and certifications to treatment/disposal facilities.
Generator Status and Waste Characterization
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Generator status determination | Current generator status (VSQG, SQG, LQG) is correctly determined based on actual monthly generation rates. Status is re-evaluated when generation rates change. Documentation supports the determination. |
| EPA ID number | Valid EPA Identification Number (EPA ID) is obtained and current. EPA ID is used on all manifests, reports, and correspondence. If generator status changed from VSQG, an EPA ID was obtained before shipping waste. |
| Waste characterization | All waste streams have been characterized through testing or process knowledge. Hazardous waste determinations are documented with supporting analytical data or process knowledge documentation. Waste codes are correctly assigned. |
| Waste stream inventory | Complete inventory of all hazardous waste streams is maintained. Each waste stream has an assigned waste code, typical generation rate, and accumulation location. New processes or materials are evaluated for waste characterization. |
Accumulation and Storage
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Accumulation time limits | Waste is shipped off-site within applicable time limits: 270 days for SQGs (or 90 days for LQGs). Accumulation start dates are clearly marked on all containers. Extensions for transportation distances over 200 miles are documented if applicable. |
| Satellite accumulation areas | Satellite accumulation areas (SAAs) are at or near the point of generation. No more than 55 gallons of hazardous waste (or 1 quart of acutely hazardous waste) per waste stream per SAA. Containers are in good condition and compatible with waste. |
| Container management | All containers are closed except when adding or removing waste. Containers are in good condition with no leaks or corrosion. Containers are compatible with the waste they hold. Weekly inspections are conducted (LQG) or as appropriate for generator status. |
| Labeling and marking | All containers are labeled with the words 'Hazardous Waste,' the accumulation start date, and the applicable waste codes. Labels are legible and visible. DOT markings are applied before transport. |
Manifesting and Recordkeeping
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Manifest completion | Uniform Hazardous Waste Manifests (EPA Form 8700-22) are properly completed for all off-site shipments. Generator information, waste descriptions, handling codes, and container counts are accurate. Electronic manifesting (e-Manifest) is used where required. |
| Manifest tracking | Signed copies are returned from the designated facility within 35 days (or 45 days for e-Manifest). Exception reports are filed with EPA/state if signed copies are not received within 35/45 days. All manifests are retained for at least three years. |
| Biennial report | Biennial Report (EPA Form 8700-13A/B) is submitted by March 1 of each even-numbered year (LQGs). Report accurately reflects all hazardous waste generated, shipped, and managed during the reporting period. |
| Land Disposal Restrictions | LDR notifications and certifications accompany the first shipment of each waste stream to a treatment/disposal facility. Records document that waste meets applicable treatment standards or is being sent for proper treatment. |
Training and Emergency Preparedness
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Personnel training | All personnel who handle hazardous waste have completed initial and annual refresher training within required timeframes. Training covers waste handling procedures, emergency response, and regulatory requirements. Training records include name, job title, date, and description of training. |
| Emergency procedures | Contingency plan (LQG) or emergency procedures (SQG) are in place and current. Emergency coordinator is designated and contact information is posted. Arrangements with local emergency responders are documented. |
| Emergency equipment | Required emergency equipment (fire extinguisher, spill kit, communications device) is available and maintained. Equipment is tested and inspected per schedule. Access to emergency equipment is unobstructed. |
Corrective Actions
Common Issues and Responses
- Incorrect generator status: Immediately re-evaluate monthly generation rates and correct the generator status determination. Implement all additional requirements of the correct status category. Consult state agency about potential disclosure.
- Missed accumulation deadlines: Arrange immediate shipment of over-accumulated waste. Document the exceedance and corrective actions taken. Review scheduling procedures to prevent recurrence.
- Incomplete manifests: Correct manifest errors through manifest discrepancy procedures. File amended manifests as needed. Retrain personnel on proper manifest completion.
- Training deficiencies: Schedule immediate training for all personnel with gaps. Update training records and implement tracking system for future compliance. Consider annual refresher training calendar reminders.
- Missing waste characterization: Arrange analytical testing for uncharacterized waste streams. Document all determinations with supporting data. Review new materials purchasing procedures to trigger waste evaluations.
Download the Free Checklist
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Download Checklist (.docx)Ecesis EHS Software
Waste Management
Track hazardous waste from generation through disposal with manifest management.
Inspections
Digital inspection forms for container conditions, labeling, and accumulation areas.
Compliance Calendar
Track accumulation deadlines, biennial report dates, and training due dates.
Training
Manage RCRA training requirements and track certifications for waste handlers.
Document Management
Centralized storage for manifests, waste profiles, LDR notifications, and audit records.
Task Management
Assign and track corrective actions identified during RCRA audits.
