Regulations & Inspections
All hazardous waste generators must comply with basic management requirements that provide for the safe handling and proper disposal of all hazardous waste.
Additional requirements apply to certain generator size categories, which are determined by the quantity of waste generated monthly. The larger the generator, the more extensive the requirements.
To ensure compliance, hazardous waste generators are subject to unannounced inspections. Ramsey County inspectors will work with your business to ensure compliance.
Rules
The Minnesota Hazardous Waste Rules are based on the federal hazardous waste rules. As the federal government adopts new rules or amends existing rules, the state of Minnesota revises its rules. The state can choose to be more stringent than the federal government in its regulation of hazardous waste generators.
In turn, Ramsey County adopts the state rules in the county’s hazardous waste management ordinance (PDF).
We recommend using the Minnesota Pollution Control Agency's fact sheets to learn more about the state's hazardous waste rules.
Generator size
There are three classifications of hazardous waste generators. Your classification is determined by how much hazardous waste your business generates each month. Certain wastes do not count toward generator size, such as used oil, lead acid batteries, and fluorescent lamps.
Large Quantity Generator (LQG)
Generates 2,200 pounds or more/month of hazardous waste (about 4 drums liquid).
Small Quantity Generator (SQG)
Generates greater than 220 pounds but less than 2200 pounds/month of hazardous waste (about ½ to 4 drums liquid).
Very Small Quantity Generator (VSQG)
Generates 220 pounds or less/month of hazardous waste (about ½ drum liquid or less).
Types of inspections
All Ramsey County hazardous waste generators are inspected. Inspections are unannounced and conducted for many reasons, primarily to review your hazardous waste management. While inspections are regulatory in nature, your inspector wants to work with your business to provide the education and technical assistance you need to better understand the hazardous waste rules.
Initial inspection
- Your business' first hazardous waste inspection.
- Typically occurs when the county licenses your site for hazardous waste generation.
Routine inspections
- Based on your business' industry risk category and last inspection date.
- Industries that generate wastes that have a greater environmental risk, if not properly managed, are inspected more frequently.
Follow-up inspections
- Occur when a significant violation is noted or when an inspection was incomplete.
- To avoid an incomplete inspection, have knowledgeable back-up or alternates, in case you are unavailable.
Complaint inspections
- Done in response to a complaint about your business.
- The county’s approach is neutral, discussing the complaint with your business to understand and resolve the situation.
Closure inspections
- Happens when your business is leaving a site.
- All hazardous wastes and hazardous materials must be removed before you leave; you cannot take your hazardous waste with you to a new location.
- You are required to schedule a closure inspection, which documents site conditions, prior to leaving.
What to expect during inspections
A typical inspection involves a walk-through of your site, a record review and a discussion of the findings and a complete inspection report.
Site walk-through
The inspector will want to visit all areas where waste is generated, handled, processed, treated and stored and the presence of emergency equipment. During the walk-through, the inspector may ask other personnel questions about the processes or wastes generated in their work areas. They will take notes and sometimes will take pictures.
Record review
During the record review, your inspector will want to see:
- Waste disposal manifests, shipping papers and recycling receipts.
- Weekly container inspection logs.
- Waste evaluation information.
- Training records for Small or Large Quantity Generators.
- Contingency plans for Large Quantity Generators.
Records must be kept on-site for a minimum of three years. Keeping records well-organized and accessible keeps the inspection time to a minimum and improves your ability to comply with record-keeping requirements.
Inspection findings
When the inspection is done, your inspector completes an inspection report, explains the findings and the expectations of your business. If violations are noted, you will need to follow-up with a response outlining your plan for addressing these issues. Depending on the violation, you may want to submit additional documentation, such as a photograph or evaluation report, with the response.
Consider doing your own inspections at your site on a regular basis. This helps you stay in compliance by routinely performing a walk-through and noting any issues that need further attention.
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