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Keep Good Records

Medium- and large-quantity generators (MQGs and LQGs) must keep records. Small-quantity generators (SQGs) can also benefit from keeping these records, although they are not required to do so. 

Dangerous Waste Regulations Checklist includes a section of recordkeeping requirements for medium and large generators.

The table below includes a list of records that businesses must keep. 

Type of Dangerous Waste Records Who’s required to have these? Kept for at least…?

Dangerous Waste Annual Reports

Businesses with a RCRA Site ID#

5 years (On-line storage in Turbo Waste OK)

RCRA Site ID # Form

LQGs and MQGs (required), some SQGs

5 years (On-line storage in Turbo Waste OK)

Waste designation records: Proof of waste types, such as test reports, MSDS, or other documents that support generator knowledge

Everyone

5 years

Shipping papers (See Transportation.)

LQGs, MQGs

5 years

Uniform Hazardous Waste Manifests (UHWM)

LQGs, MQGs

5 years

Bills of lading, or other shipping receipts

Everyone, when the UHWM is not required.

Recommended for SQGs

5 years

Spill response plan

LQGs

Ongoing

Employee Training Plan and Records

LQGs

Ongoing - employees
3 yrs - former employees
Spill Reports LQGs, MQGs 5 years

Emergency plan (See Planning for Emergencies)

LQGs

Ongoing

Training records on emergency preparedness

LQGs

5 years

Weekly Inspection logs for dangerous waste accumulation areas

LQGs, MQGs

5 years

Solvent-recycling (still) logs

Everyone who uses a still 5 years

Financial Assurance Records

LQGs 5 years
Exception reports

LQGs, MQGs

5 years
Documents associated with the use of drip pads

LQGs, MQGs

5 years
Logs showing date and amount of waste treated on site

LQGs, MQGs

5 years
Documents associated with the use of containment buildings

LQGs, MQGs

5 years
Waste analysis plans when treating waste for LDR purposes

LQGs,

5 years
Waste analysis plans when treating waste in a permit-by-rule (PBR) unit Everyone treating waste in a PBR unit 5 years
On-site facility inspection reports, logs, and schedule

LQGs, MQGs

5 years

Written Contingency Plan

LQGs,

5 years
Documentation of claims that materials are not solid waste or are conditionally exempt Everyone making such claims 5 years
Daily Tank Inspection Log Template for logging daily hazardous waste tank inspectionsMS Word | Adobe PDF For LQGs and MQGs Keep for 5 years

Recordkeeping and Reporting for Small-quantity Generators discusses what records are good for SQGs to keep.

Related information

RCRA Site Identification Number or Notification of Dangerous Waste Activities or EPA Number is required of LQGs and MQGs.

Dangerous Waste Annual Report is required of all those who have an active RCRA Site ID#.