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What to Expect in a Dangerous Waste Compliance Inspection

Inspectors show up unannounced

Dangerous waste compliance inspectors visit facilities to make sure that generators are handling, storing, and disposing of dangerous waste correctly.  They have legal authority to inspect during normal business hours and may show up unannounced. An inspection usually takes about two to three hours.

All facilities with active RCRA Site ID Numbers are subject to inspection by the Department of Ecology's dangerous waste inspectors. Inspectors choose facilities based on generator status and size of the facility, history of problems or unexplained changes in generator status, complaints, and/or referrals from other agencies.   Inspections also help prevent problems that might cause pollution. This is much easier and cheaper than trying to clean up pollution afterwards.

Have records on hand

The inspector first asks to see the site contact listed on the notification form or annual report. Inspectors check records relating to dangerous-waste management, such as transport manifests, storage logs and inspections, safety equipment inspections, and employee training.

Inspectors look at production areas, 90- or 180-day accumulation areas, satellite accumulation areas, and “bone yards” or other storage areas. The inspector will take pictures of any violations found, and of examples of proper dangerous waste management.

The exit conference and compliance certificate

The inspector holds an exit conference with the facility representative. Afterwards, the inspector writes up an inspection report and compliance certificate and mails them to the facility. The compliance certificate has:

1. The violation cited,
2. A summary of any problems, with directions on how to fix them, and
3. A compliance deadline date.

The facility representative completes the compliance certificate, showing what was done to correct any violations, and returns it to Ecology.

Penalties?

Normally, Ecology does not fine facilities if problems are fixed by the deadline. Ecology offers technical assistance to help facilities resolve problems. However, if a facility does not correct problems, formal enforcement may be necessary. This is normally an administrative order to comply with a monetary penalty based on the violations. Each violation can result in a penalty of up to $10,000 per day.

Penalties are likely if the generator refuses to get into compliance, future inspections show the same problems recurring, or violations damage human health and / or the environment.

Related information

Guide for Dangerous Waste Generators in Washington State: Quick Reference Guide shows the most important dangerous waste management requirements for generators in a simple, table format.