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Hazardous Waste Inspection Tips
Sections 25185 and 25508 of the California Health and Safety Code requires CUPAs to inspect facilities that handle hazardous materials and/or generate hazardous wastes. To this end, SW/HM follows general guidelines for completing thorough inspections. The following are some of the things that you should expect when an inspection occurs and steps you can take to help the inspection proceed smoothly and quickly. Remember: Inspections need not be time-consuming or overly intrusive. With your help, our inspectors can perform their duties while also helping your facility with hazardous material and waste regulatory compliance, and safeguarding worker and environmental health.
Expect Unannounced Inspections
Because of the regulatory nature of our inspections and the uncertain time frames involved with each facility, you should expect unannounced inspections.
A general walk-through of the facility to look at processes and storage areas is a standard part of an inspection. The inspector will ask general questions about the facility, where hazardous materials are kept and how wastes are generated. Keep areas where hazardous materials and wastes are located clean. Not only is it easier to complete the inspection when the areas are clean and dry, but good housekeeping procedures can also prevent workplace injuries such as slips, trips and falls, and help in reducing worker compensation claims. Keep labels facing out and make sure hazardous waste labels are complete and include the accumulation start date. Handling and accumulating hazardous material and waste is serious business. Just because you may use these substances everyday, don't become complacent and lapse in the proper safe handling of these hazardous substances. They are called hazardous for a reason: potential fire, explosions, inhalation hazards and long term health problems can result from the mishandling of these substances.
Keep all hazardous materials and waste records (receipts, invoices, manifests, etc.) in one file. If this is not possible, create a file labeled "Hazardous Waste" and put a list of where the records can be found. Photocopies of records are acceptable as long as they are legible and the originals can be produced if needed. All hazardous waste records must be kept for a minimum of three (3) years. Other records that may be necessary include Business Emergency Plan, employee training records, storage area checklists, underground storage tank records, SPCC plans, SB 14 and recycling records.
After the inspection, we will go over any areas that need correction and a report will be issued to you at that time, or mailed to you at a later date. Pay close attention to the amount of time given to correct any violations and paperwork that may need to be submitted. Failure to correct violations noted may results in legal action. If you cannot meet the deadline, contact your inspector well in advance of the compliance date.
Inspections go more quickly if every question has an honest, immediate answer; however, we understand that one person may not have the answers to all of our questions. In such circumstances, "I'm not sure, I'll find out", earns a lot more credibility than vague, deceptive-sounding answers.
Contrary to what you may have heard, your inspector is not "out to get you". Our inspectors pride themselves on being education and compliance oriented, not enforcement oriented. What that means to you as a regulated facility is that we usually do not fine or impose penalties at first; we try to educate you in the proper handling of your hazardous material and waste. However, for those facilities that have received a Notice of Violation and choose to disregard it, or who purposely violate hazardous material and waste laws, the state gives SW/HM the authority to levy fines and penalties, as well as filing a case with the District Attorney's Office with charges ranging from civil penalties to criminal misdemeanors and felonies.
Click Here for information regarding filling out a Hazardous Waste Label.