Hazardous Waste Program

Inspections

From the archives of the Enforcement and Compliance Listserv for Hazardous Waste Generators

Aug. 24, 2012

Inspection Checklists Online!

The Missouri Department of Natural Resources has checklists to help you! 

The Small Quantity Generator Supplemental Inspection Checklist helps small quantity generators who store 1,000 kilograms (2,200 lbs) or more of hazardous waste at their facility to identify the extra requirements that they must meet in Missouri such as having a personnel training plan and a contingency plan.

Small Quantity Generator Supplemental Inspection Checklist

The Electronic Scrap Recycler Inspection Checklist is for businesses that recycle electronics.

Electronic Scrap Recycler Inspection Checklist

July 30, 2007 

What to Expect When We're Inspecting.

I am going to let you in on a secret. Most hazardous waste compliance inspections are based on the information you do (or do not) report to the Missouri Department of Natural Resources. The department uses information submitted by generators to distribute inspections among the three generator levels, Conditionally Exempt Small Quantity Generator, or CESQG, Small Quantity Generator, or SQG, and Large Quantity Generator, or LQG. In addition to the random inspections, the department often visits locations for the following reasons:

- for failing to register with the department if your business generates a
  regulated amount of hazardous waste (100 kgs or 220 pounds or more
  generated in a month or stored on-site).
- when a SGQ or LQG fails to submit its required reporting or hazardous
  waste fees on time.
- a change in generator status, for instance a Small Quantity Generator to a Large Quantity Generator.
- in response to a complaint.

Prepare for an Inspection

Be proactive and prepare for an inspection. We suggest using the department's inspection checklists to perform a self-inspection of your business.
For SQG businesses, use /forms/780-1602-f.pdf. For LQG businesses, use /forms/780-1525-f.pdf. Ask yourself the tough questions when you perform your self-inspection. Are your hazardous waste containers closed? Are your containers properly labeled and marked? Is your satellite accumulation area in compliance? If you are not sure that you understand an item on the checklist, refer to the regulations listed under the item or review a previous listserv article on the subject by visiting our Hazardous Waste Generator Topic Archive.

Grade your business and make improvements if needed. You might even want to arrange self-inspections on a set schedule. Try the first day of your operating quarter, on payday, the last Monday of the month, or anytime that you can regularly set aside a few hours to review your operations and management of hazardous waste.

Required Inspections

Don't forget, both Small Quantity Generator and Large Quantity Generator businesses are required to inspect and maintain their waste storage areas weekly. In Missouri, hazardous waste generators must inspect storage areas for:

- malfunctions.
- deterioration.
- operator error.
- evidence of discharge.
- leaks.

Small Quantity Generator and Large Quantity Generator businesses must also inspect areas subject to spills on a daily basis including:

- loading and unloading areas.
- overfill or spill control equipment to ensure it is in working order.
- the above ground portion of equipment for corrosion and release.
- data from monitoring or leak-detection equipment to ensure that the tank
  system is being operated according to design.
- the area around tank systems, including secondary containment structures
  such as dikes, for erosion or signs of release (for example wet spots or
  dead vegetation).

September 7, 2005

Useful Inspection Information:

Never been inspected? Many hazardous waste generators have never been inspected so it is important that you to know what to expect. Correcting problems before an inspection helps you comply and helps us serve you better. Check out a copy of the actual inspection checklist our inspectors use to review facilities and do a "practice" inspection for yourself.

If you would like to unsubscribe to this e-newsletter, please visit the department's Enforcement and Compliance Assistance Newsletter Generators Subscription.  If you know of anyone else who would like to be added to this listserv, visit the department's Enforcement and Compliance Assistance Newsletter Generators Subscription to sign up.

If you need further assistance, email or contact the Department of Natural Resources' Hazardous Waste Program at 573-751-7560 or 800-361-4827.

Return to listserv topics at the Hazardous Waste Generator Archive