Managing your company’s environmental programs involves complying with regulations from multiple agencies. One such agency, the California Department of Environmental Health, typically conducts annual inspections of a company’s hazardous waste program. These inspections can be stressful, as most inspectors will arrive onsite with no warning. Maintaining compliance with all the regulations enforced by DEH can be quite the task. To make it a little easier on you, here is a list of the most common areas of non-compliance to keep in mind:
1) All hazardous waste containers must be properly labeled, complete with an accumulation start date.
2) Hazardous waste containers must be fully closed at all times, except when adding or removing waste.
3) All waste containers must be disposed of within the allowable accumulation times (180 days for Small Quantity Generators and 90 days for Large Quantity Generators).
4) Accumulation in satellite containers cannot exceed one year.
5) HMBP must be kept up to date.
6) Copies of all hazardous waste manifests must have been mailed to the DTSC.
7) TSDF-signed copies of manifests must have been received for all hazardous waste shipments. These must be kept available for inspection for a minimum of three (3)
8) All medical waste containers must be properly labeled, including generator’s name, address and phone number (applies to San Diego County).
9) Medical waste tracking documents for the past three (3) years are available for inspection.
10) All red biohazard bags must be kept in rigid, leak-resistant containers that are kept clean.
The County of San Diego has provided a self-audit checklist to assist with conducting weekly inspections. This checklist also provides more details on labeling and storage requirements:
Should you need additional assistance with compliance, ACTenviro has an experienced EHS team at your disposal. You may visit our website for more details:
We look forward to serving you!
– Vanessa Clark, Account Manager