WASTE MANAGEMENT PLAN CHECKLIST
(NOTE: This checklist assumes you are a Large Quantity Generator and generate more than 2200 pounds of hazardous waste in any month during the year. If you are a Small Quantity Generator or Conditionally Exempt SQG, your requirements are fewer.) DIRECTIONS: Place a checkmark at each item you know you have fully prepared. Place a zero at each item that you lack or know to be incomplete. Total the results and see where you are on a day-to-day basis or in being ready for a compliance inspection.

___ A separate file drawer just for your environmental program files.
(Not required, but you’re ahead of the game if you have this at your facility!)

___ An up-to-date list of all hazardous wastes generated.
___ An up-to-date, OEPA Generator Notification form on file.
___ A monthly calendar or other diary indicating waste generation totals.
___ Complete, written job descriptions on file for every person in waste management.
___ A list of workers, by process area, with a responsibility in waste management.
___ Process Flow Diagrams for each process generating hazardous waste.
(Not required, but you’re ahead of the game if you have completed these!)
___ A facility map indicating waste generation and storage areas.
___ A file folder for every waste generated by your facility, complete with detailed information that determines whether that waste is hazardous or non-hazardous.
___ A file folder containing the results of your weekly hazardous waste inspections.
___ Initial / Annual RCRA training records, including class syllabus, dates of training, and employee sign-in sheets.
___ Records of in-progress and completed waste manifests and LDRs for every shipment.
___ A written Satellite Accumulation Plan.
___ A written Universal Waste Management Plan.
___ A written Used Oil Management Plan.
___ A written Waste Minimization Plan.
___ A written and up-to-date Contingency Plan.
___ A written Emergency Preparedness Plan (Generally in your Contingency Plan).
___ An annual record of a practice implementation of your Contingency Plan and testing of emergency equipment identified in the Emergency Preparedness Plan.
___ A copy of your most recent annual hazardous waste Generator Report.
___ A file containing audit records for the waste transporters and disposal facilities employed, including permits, insurance certificates and EPA inspection results. (You’re very thorough if your company has personally visited each waste facility!)
___ Your environmental file has complete records for at least the last three years.

Now generate your score: Total checkmarks_____ Total zeroes_____

How do your totals look? The totals will give you a good idea about how your WMP stacks up and your readiness for an inspection. If you need to start a plan from scratch, it will take some work to complete a good one. After that, you make WMP adjustments only as necessary. If you need help on your WMP, click here to contact a CTI associate.