Hazardous Waste Audit Checklist
Large Quantity Generator
Campus:
Audit Date:
Auditor:
yes
no
n/a
comments
Generator Size Determination
1 Does the facility produce greater than 1000
Kilograms (2200 pounds) of hazardous waste per
month?
2 Does the facility produce greater than 1
Kilograms (2.2 pounds) of acutely hazardous
waste per month?
Hazardous Waste Determination
1 Has an accurate hazardous waste determination
been made on all solid wastes by utilizing the
following criteria:
 Is it excluded under 261.4?
 Is it excluded in subpart D of 261 or
appendix XI of 261?
 Has the waste been analyzed?
 Has generator knowledge of the hazard
characteristics of the waste in light of the
materials used been applied?
 Have other regulatory exclusions and/or
restrictions been applied?
Documentation
1 Does the generator have an EPA ID number?
2 Does the generator only offer waste to TSDs who
are permitted and have an EPA ID number.
3 Has the generator filed a new form 2701 upon
generation of a new waste stream at his site?
4 Have wastes that have been newly classified or
listed hazardous been reported on form 2701?
5 Has a new form 2701 been filed each time its
contents becomes outdated?
6 If company no longer produces hazardous waste
has DHEC been notified through submission of a
form 2701?
7 Does the generator file quarterly reports as
required?
8 Does the generator maintain quarterly reports
onsite for a minimum of three years?
9 Is a waste minimization report filed by January
31 each year?
10 Are waste minimization reports maintained
onsite for a minimum of three years?
11 Is a copy of the manifest maintained onsite for
three years?
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12 Are test results, waste analysis or other waste
determination documentation maintained onsite
for three years?
13 If a signed copy of a manifest has not been
received within 35 days was the designated
facility contacted to determine the status of the
waste?
14 If a signed copy of the manifest was not received
from the transported within 45 days was an
exception report filed with DHEC that included a
legible copy of the manifest and a description of
actions taken to determine the status of the
waste?
15 Are land disposal requirements (LDRs) met as
outlined in R.268?
16 Are LDRs maintained onsite for three years?
17 Does the generator us a uniform manifest when
shipping hazardous waste offsite?
18 Does generator designate on the manifest one
facility which is permitted to handle the waste?
19 If necessary, does generator designate an
alternate facility?
20 Does the generator use a permitted transporter to
ship waste off-site?
21 Is the manifest completed as required by the
instructions printed on back:
 Generator’s name, address, phone number,
and ID number?
 Name and ID number of each transporter
 Name, address and ID number of designated
facility and, if any, alternate facility?
 DOT description of waste
 Total quantity if each waste by units of
weight and the type and number of
containers as loaded onto the transport
vehicle?
 Items 19 and 35: Discrepancy indication
space - does the TSDF enter that actual
weight in pounds in this space it the amount
varies any from that specified by the
generator or if the generator uses units of
measure other than pounds.
 Have items A-K and L-T been completed?
 Does the SC generator’s certification appear
on the manifest?
 Does the generator sign the manifest
certification by hand?
 Obtain handwritten signature from the initial
transporter and date of acceptance?
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
Does generator retain one copy?
Note: Manifests do not have to be used to transport waste on public or private rights of way
within or along the border of contiguous property
Storage
1
Before transporting, or offering for transport,
does generator mark each container of 110
gallons or less with the following:

2
3
4
5
6
7
8
9
10
11
12
13
HAZARDOUS WASTE – federal law
prohibits improper disposal. If found,
contact the nearest police or public safety
authority or the U.S. Environmental
Protection Agency
 Generator’s name and address
 Manifest document number
 Accumulation start date
Has hazardous waste been accumulated onsite
for greater than 90 days?
If waste is stored greater than 90 days did
generator request an extension?
Does generator comply with subparts C and D
(Preparedness, Prevention, Contingency Plans,
and Emergency Procedures) of section 265?
Is each storage container marked with an
accumulation start date and EPA hazardous
waste number?
Is there always at least one person on the
premises or on call to act as emergency
coordinator?
Is the name and telephone number of the
emergency coordinator, Location of fire
extinguishers, spill control equipment, and if
present, fire alarm, the telephone number of the
fire department unless the facility has a direct
alarm
Are all employees trained in waste handling and
emergency procedures relevant to their
responsibilities during normal and emergency
operations?
Are all containers in good condition?
Are all containers compatible with the waste they
contain?
Are all containers closed except when adding or
removing waste?
Are containers handled in a way that prevents
rupture or leaking?
Are containers stacked no more than two
containers high?
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14 Is each container marked with the following or
equivalent statement: “Hazardous waste – federal
laws prohibit improper disposal.”
15 Is each container marked with an EPA waste
number
16 Is each container marked with an accumulation
start date?
17 Are incompatible waste separated by a physical
barrier?
18 Does the owner/operator maintain adequate aisle
space to allow the unobstructed movement of
personnel, fire protection equipment, spill
control equipment, and decontamination
equipment to any area of the facility operated in
an emergency?
19
For areas where liquid waste is stored:

Is there a base under containers which is free
of cracks and gaps, and is sufficiently
impervious to contains leaks of hazardous
waste and accumulated precipitation
 Is the base sloped to remove spillage or
accumulated precipitation?
20 Does the containment system have sufficient
volume to contain 10 % of the volume of the
containers or 100% of the volume of the largest
container?
21 Is run-on prevented unless there is sufficient
excess capacity to contain it?
22 Is run-on prevented, unless there is sufficient
excess capacity?
23 Is spilled or leaked waste and precipitation
removed in a timely manner?
24 For areas where wastes without free liquids are
stored is the storage area sloped or otherwise
designed and operated to remove precipitation or
other liquids?
25 Are containers elevated to prevent contact with
accumulated liquid?
Satellite accumulation
1 Does generator accumulate no more than 55
gallons of hazardous waste or nor more than one
quart of acutely hazardous waste at or near the
point of generation?
2 Does generator remove any waste in excess of 55
gallons from satellite accumulation to storage
within 72 hours of exceeding 55 gallons?
3 Are containers in good condition?
4 Are containers compatible with the waste that
they hold?
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5
Is the container kept closed except when adding
or removing waste?
Is the container marked either as “hazardous
waste” or other words that identify its contents?
7 Do facility personnel complete classroom or on
the job training that teaches them to perform
their duties in a way that ensures compliance?
Training
1 Is the training program designed to ensure that
personnel are able to respond effectively to
emergencies, including the following:
 Procedures for using, inspecting, repairing
and replacing emergency and monitoring
equipment
 Communications or alarms systems
 Response to fires or explosions
 Response to groundwater contamination
 Shutdown of operations
2 Is the training performed by an individual trained
in hazardous waste management?
3 Are records of training maintained onsite for
three years?
4 Are new employees trained within three months?
5 Is training renewed annually?
6 Are training records maintained until facility
closure or for three years for former employees?
7 Are the following hazardous waste training
related records maintained at the facility:
 Job title for each position related to
hazardous waste management
 Written job description related to hazardous
waste management
 Written description for the type and amount
of initial and continuing training
8 Records that demonstrate that the training has
been completed
Inspections
1 Are all areas where containers are stored being
inspected at least weekly for compliance with
regulatory requirements?
2 Are inspections documented and maintained
onsite?
6
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3
Does the inspection log include the name of the
inspector, the date and time, a notation of any
observations made and the date and nature of any
repairs or remedial actions taken?
Emergency Response
1 Is the facility equipped with the following:
 Internal communication or alarm system
capable of providing immediate emergency
instruction? Telephone or two way radio
immediately available at the scene of
operation capable of summoning emergency
assistance from police, fire of emergency
response teams?
 Portable fire extinguishers, fire control
equipment, spill control equipment, and
decontamination equipment
 Water at adequate volume and pressure?
2 Is the emergency equipment tested and
maintained as necessary?
3 Do employees who handle hazardous waste have
immediate access to an alarm or emergency
communication device?
4 When employees work alone do they have
immediate access to a phone or two-way radio
capable of summoning emergency assistance?
5
 Has the facility made the following
arrangements:
 Arrangements to familiarize police, fire and
emergency response teams with the layout of
the facility, properties of the hazardous
waste that is handled, places where
employees would normally be working,
entrances to the facility and evacuation
routes?
 Agreements with police and fire departments
designating a primary emergency authority?
 Agreements with State emergency response
teams, emergency response contractors and
equipment suppliers?
 Arrangements to familiarize local hospitals
with the properties of hazardous waste
handled at the facility and the types of
injuries or illnesses which could result from
fires, explosions, or releases?
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
6
7
8
9
10
11
12
13
14
15
Where State or local authorities decline to
enter into such arrangements, has the facility
documented the refusal in his operating
record?
Does the facility have a contingency plan?
Are the provisions of the contingency plan
carried out immediately in the event of an
emergency?
Does the plan describe arrangements agreed to
by local police, fire depts, hospitals, contractors,
and State and local emergency response teams to
coordinate emergency services?
Does the plan have an updated list names,
addresses, and phone numbers (office and home)
of all persons qualified to act as emergency
coordinators.(Where more than one person is
listed, one must be designated as primary.)
Does the plan contain:
 A list of all emergency equipment at the
facility?
 A brief description of the equipments
abilities?
 Location of the equipment at the facility?
Does the plan include an evacuation plan that
includes the following:
 A description of signals used to begin an
evacuation?
 Evacuation routes?
 Alternate evacuation routes?
Is a copy of the plan maintained at the facility?
Is a copy submitted to all local police, fire depts,
hospitals, and State andlocal emergency response
teams that may be called upon for emergency
services?
Is the plan reviewed, and amended, whenever:
 Regulations are revised
 The plan fails
 The facility changes in its design or
construction
 The list of emergency coordinators changes
 The list of emergency equipment changes
Is a qualified person on call at all times to act as
emergency coordinator?
USC EHS Office of Environmental Management
EHS-F-187
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Issue Date: 6/18/07
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