RCRA (Resource Conservation and Recovery Act) Key Inspection Points for Satellite Accumulation Areas (SAA)
- 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.
- 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.
- Annual hazardous waste training required for anyone generating hazardous waste.
- Annual Responsible Management of Hazardous Waste Training