What are the required records?

• Treatment, storage, and disposal facilities are required to keep detailed operating records.
• Required records for SQGs and LQGs include waste characterization, manifests, LDR paperwork, and training records.
• Annual reports must be completed by hazardous waste generators that export hazardous waste to a facility outside of the United States.

Generator status determines how much paperwork must be completed and filed. Operating record: Treatment, storage, and disposal facilities are required to keep detailed operating records (as described in part 264). While the Environmental Protection Agency (EPA) references operating records for small quantity generators (SQGs) and large quantity generators (LQGs), the agency doesn’t define the term for generators. Instead, think of all the required records as an operating record.

These required records include:

• Waste characterization: All generators must keep all waste analyses, test results, or waste determinations from the last date that the waste was sent offsite, and any other waste reports for three years.
• Manifests: SQGs and LQGs must keep signed copies of manifests and any exception reports for three years.
• Land Disposal Restriction (LDR) paperwork: SQGs and LQGs must keep copies of all LDR paperwork, including initial notices, certifications, waste analysis data, and other documentation related to waste treatment and disposal for at least three years from the date the waste that is the subject of the documentation was last sent to the disposal facility.
• Training records: SQGs and LQGs must keep training records for current employees until closure of the facility. Keep records for former employees for at least three years from the date the employee last worked at the facility.

SQG “re-notifications”

EPA and the states are aware of LQG hazardous waste activities because of the biennial report. EPA is now requiring SQGs to submit “re-notifications” to the state beginning in 2021 and every four years thereafter.

Note that some states already have more stringent reporting requirements. They may require annual reporting and/or may require SQGs and very small quantity generators (VSQGs) to report.

Annual reports for exporters

Annual reports must be completed by hazardous waste generators that export hazardous waste to a facility outside of the United States. The report is required by EPA to keep track of all shipments of hazardous waste leaving the country.

An annual report must be filed no later than the first of March of each calendar year, and must summarize the types, quantities, frequency, and ultimate destination of all hazardous waste exported during the previous calendar year. The facility’s EPA identification number is also required on the report. There is no actual form for this, but the regulation at 262.56 explains the requirements.