RCRA-Satellite Accumulation Area Checklist

RCRA (Resource Conservation and Recovery Act) Key Inspection Points for Satellite Accumulation Areas (SAA)
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  • Weekly Inspections:
    • Inspect all waste containers for proper labeling, leaks, etc. once per week.
    • As a best practice, consider using this checklist form as a guide.
  • The Satellite Accumulation Area Location:
    • SAA must be located at or near the point of generation.
    • SAA must be under the control of the person generating the waste. 
  • Waste Transportation:
    • Hazardous waste is not transported between rooms.
    • Central Accumulation Areas must be approved by ESD.
  • Waste Container Condition:
    • Containers holding the wastes must be in good condition with no rusting, cracking, wearing, bulging, etc.
    • All chemical containers are properly labeled and in good condition.
  • Waste Container Compatibility:
    • Hazardous wastes must be stored in containers made of compatible materials (i.e. acid and alkaline wastes should not be stored in metal containers).
  • Waste Containers Must Stay Closed:
    • Containers must be kept closed with a properly fitting cap except when adding or removing hazardous waste (i.e. funnels removed and caps tightly secured).
  • Waste Quantity Limits:
    • No more than 55-gallons of hazardous waste and/or one quart of acutely hazardous waste
    • (P-listed and certain F-listed waste) allowed in each SAA.
    • Hazardous waste containers are considered full at 90% total volume.
    • If your SAA is approaching these limits, a pick-up request should be made immediately via Chematix.
  • Waste Container Labeling:
    • Old labels must be removed when reusing the container as waste storage.
    • The container must be marked with the words “Hazardous Waste.”
    • Labels on waste containers should not have dates
    • Labels must contain full chemical names of all chemicals added
    • For mixtures, the percentage of each component is listed and the total adds up to 100%
    • Peroxide formers must be labeled properly with received date listed on the front of the container.
  • Waste Container Storage:
    • Containers must be handled and stored in a manner which prevents rupturing or leaking.
    • Secondary containment is required for all aqueous hazardous waste   containers.
    • Incompatible waste materials are not stored together.
    • SAA must be located away from sinks and floor drains.
  • Personal Protective Equipment:
    • Proper PPE must be worn while handling hazardous wastes.
    • This includes gloves, safety glasses, lab coat, face shield, etc.
    • PPE should be selected after consulting the appropriate material safety data sheets.
  • Training: