Waste Compliance & Common Violations
Texas Commission on Environmental Quality (TCEQ) Investigators often observe violations during Industrial and Hazardous Waste (IHW) compliance evaluations and investigations.
Here are some Common Issues:
Waste Management:
- Failure to conduct weekly inspections of the container storage area.
- Failure to properly label containers of paint and paint related waste managed as universal waste.
- Failure to close containers of of hazardous waste when not adding or removing waste.
- Failure to properly date universal waste containers/or maintain a correct record of the accumulation date.
- Failure to have containers clearly marked and visible with accumulation start date.
- Failure to have containers labeled "Hazardous Waste".
Operating Records:
- Failure to update the Notice of Registration to reflect current waste management activities.
- Failure to maintain a complete and correct Annual Waste Summary.
- Failure to correctly complete manifests.
- Failure to maintain hazardous waste determinations and classifications.
- Failure to maintain job descriptions, job titles, and employee names for positions related to hazardous waste management.
- Failure to make arrangements with local authorities relating to the properties of hazardous waste handled at the facility and associated hazards.
- Failure to maintain a contingency plan — SPCC and emergency plans.
More information can be found from below TCEQ links:
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