PNEAC Fact Sheet
Basic RCRA Record Keeping Requirements for Printers
By Debra Jacobson, PNEAC

The Resource Conservation and Recovery Act (RCRA) of 1984 gave the U.S. Environmental Protection Agency (EPA) the authority to regulate municipal and hazardous waste. The purpose of this fact sheet is to provide a basic understanding of the various recordkeeping requirements mandated by EPA. Depending on state and local requirements, additional recordkeeping requirements and longer record retention requirements may apply .

Recordkeeping:

The information below is a starting point for determining if your RCRA required records are in order. Since paperwork is one of the easiest noncompliance issue to spot during an EPA audit, keep your paperwork in order. Here are some records to keep.

EPA Identification Number / Notice of Hazardous Waste Activity (40 CFR 262.11)

Prior to offering hazardous waste to transporters or treatment, storage, or disposal facilities a generator must obtain a EPA (waste generator) identification number. The facility must complete EPA form 8700-12 and submit it to the Agency. Copies of the application and notification/assignment of the facilities assigned identification number must be kept on file. No specified record retention period. Note, this number does not expire or change, unless the facility relocates.

Hazardous Waste Storage and Accumulation(40 CFR 262.34)

Facilities that generate greater than 221 lbs per month (SQG & LQG) of hazardous waste are required to train affected employees on proper waste handling and emergency procedures, maintain documentation on waste handling procedures, which includes designated emergency response personnel; documentation on duration and date of waste storage, and a written storage time compliance procedure. No specified record retention period.

Manifests and Land Disposal Notification (40 CFR 262.40)

Facilities that generate greater than 221 lbs per month (SQG & LQG) of hazardous waste are to maintain copies of each signed manifest. One copy should be retained when the waste is transported from the facility and the second copy must be signed and supplied by the disposal facility within 45 days after the waste leaves the generator's facility. The facility's manifests or the signed manifests from the treatment storage and disposal facility receiving the hazardous waste are to be retained for 3 years.

Records of test results, waste analyses, or other determinations that the waste is hazardous must be kept for 3 years.

Biennial Report (40 CFR 262.41)

A Biennial Report (each even numbered year) must be submitted to the USEPA by Small Quantity and Large Quantity Generators no later than March 1st (on odd numbered years most states require a report be submitted to the state agency). A copy of the Biennial Report and Exception Report must be kept for 3 years.

Exception Reporting (40 CFR 262.42)

If the hazardous waste generator does not receive a signed copy of the manifest from the disposal facility within 45 days after the waste was accepted by the initial transporter, an Exception Report must be supplied to the state regulatory agency and a copy of this report must be retained with the manifest. The exception report must be retained for at least 3 years.

Hazardous Waste Minimization/Pollution Prevention Requirements (40 CFR 262 App)

Hazardous waste generators using a manifest under the "Generator’s Certification" attests to " . . . If I am a large quantity generator, I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically practicable and that I have selected the practicable method of treatment, storage, or disposal currently available to one which minimizes the present and future threat to human health and the environment; OR, if I am a small quantity generator, I have made a good faith effort to minimize my waste generation and select the best waste management method that is available to me and that I can afford." In other words a waste minimization and pollution prevention plan is required to be implemented. It is recommended that a written program be developed and retained on-site.

Hazardous Waste Storage Area Inspection (40 CFR 265.1101)

The hazardous waste storage area must be inspected at least every 7 days to monitor leak detection equipment and detect signs of releases of hazardous waste in or around the containment area. Records of weekly inspections must be maintained for at least 3 years.

Recyclable Materials (40 CFR 266.70)

Persons Who Generate or Store Recyclable Materials That Are Reclaimed to Recover Economically Significant Amount of Silver and Other Precious Metals (40 CFR 266.70): Generators must maintain manifests when material is being transported for reclamation. Persons who store these materials (non-speculatively) must keep records showing the volume of these materials stored at the beginning of the calendar year; the amount generated or received during the calendar year; and the amount of materials remaining at the end of the calendar year. No specified retention period for the documents.

Used Oil Generators (40 CFR 279.74)

Generators of used oil are to keep a record of each used oil shipment that is accepted for processing/re-refining and shipped to a used oil burner, processor/re-refiner, or disposal facility. These records may take the form of a log, invoice, manifest, bill of lading, or other shipping documents. Records are to be retained for 3 years.

Underground Storage Tanks (UST's) (40 CFR 280 & 281)

Owners and operators of new and existing USTs are to maintain records that demonstrate compliance with performance standards (monitoring, testing, protection, repairs, and closure). These records are to be maintained for the life of the tank and piping system.

Hazardous Waste Generator Status:
Conditionally Exempt SQG Small Quantity Generator Large Quantity Generator
(less than 220 lbs/month) (221-2205 lbs/month) (2205 lbs/month or greater)

If no specific records retention time is established, records should be retained for at least five years. 

Primary Author

Debra Jacobson
University of Illinois Sustainable Technology Center
djacobso@illinois.edu
630.472.5019

Other PNEAC Contacts

Gary Jones
Graphic Arts Technical Foundation
GJones@printing.org
412.741.6860

Wayne Pferdehirt
Solid & Hazardous Waste Education Center
pferdehi@epd.engr.wisc.edu
608.265.2361

Written: August 1998
Updated:

Note: Reasonable effort has been made to review and verify information in this document. Neither PNEAC and it's partners, nor the technical reviewers and their agencies, assume responsibility for completeness and accuracy of the information, or it's interpretation. The reader is responsible for making the appropriate decisions with respect to their operation, specific materials employed, work practices, equipment and regulatory obligations. It is imperative to verify current applicable regulatory requirements with state and/or local regulatory agencies.

© 1998 PNEAC