Record Keeping

Description

Records on usage of materials containing VOC's, HAP's and SARA Title 313 reportable chemicals (see for a list of HAP's & SARA 313 chemicals and SARA 313 PBT chemicals) must be maintained based on a calendar year usage. These records are required to be kept and reviewed regardless of whether the facility exceeded the reporting threshold. The purpose that requirement is to assure annual review of the usage versus the reporting threshold since chemical usage can vary from year to year.

Hazardous waste regulations, otherwise known as RCRA, requires waste generators to maintain records of all regulated waste shipments for a minimum of three years. State regulations may be longer.

Receipts or manifests for shipments of hazardous materials, empty drums and containers, etc. must be maintained for at least three years according to U.S. DOT requirements.

Copies of all analytical testing for waste streams and other materials should be retained in the environmental records.

Copies of all operating permits, application forms, and associated reports should be retained for at least five years after the permit has been renewed.

Best Management Practices & Pollution Prevention

Record keeping is an important step towards environmental compliance. It is strongly urged that every record of any purchase, every receipt, or bill of lading be kept. Businesses are required to use a manifest every time any waste, both hazardous and non-hazardous, is disposed and the manifest must be kept for at least three years (longer depending on the local/state requirements). A good, well organized record keeping system can help demonstrate compliance and determine the various sources of waste, generation rates, and provide answers for implementing a pollution prevention program.

For access to vendors who may supply alternative materials and equipment, see the PNEAC Vendor Directory.

Environmental Regulations

Records on usage of materials containing VOC's, HAP's and SARA Title 313 reportable chemicals (see for a list of HAP's & SARA 313 chemicals and SARA 313 PBT chemicals) must be maintained based on a calendar year usage. These records are required to be kept and reviewed regardless of whether the facility exceeded the reporting threshold. The purpose that requirement is to assure annual review of the usage versus the reporting threshold since chemical usage can vary from year to year.

Hazardous waste regulations, otherwise known as RCRA, requires waste generators to maintain records of all regulated waste shipments for a minimum of three years. State regulations may be longer.

Receipts or manifests for shipments of hazardous materials, empty drums and containers, etc. must be maintained for at least three years according to U.S. DOT requirements.

Copies of all analytical testing for waste streams and other materials should be retained in the environmental records.

Copies of all operating permits, application forms, and associated reports should be retained for at least five years after the permit has been renewed.

Health & Safety

Records of medical treatment, accident and illness records must be maintained each year according to OSHA regulations. Employers must use the OSHA 300A and 301 Form to document these incidents. The form must be posted for the entire month of February each year regardless of whether there were any recordable incidents or not.

Records of medical treatment, accident and illness records must be maintained each year according to OSHA regulations.

Copies of Material Safety Data Sheets must be maintained for 30 years or as long as the company is in business (whichever is longer) according to OSHA regulations.

Records of all safety training must be maintained. Records should include, but not limited to, job specific training, general awareness training, fire safety training, etc.