EHS Inspections: Focus on Hazardous Waste

May 6th, 2025 by Dakota Software Staff

Environment, Health, and Safety (EHS) inspections are essential to ensure compliance and create a strong culture of safety in the workplace. In this recurring series, we’re diving into the most common challenges facing EHS pros—and providing quick inspection tips to help address them.

Hazardous waste – Every organization generates some type of waste. Certain wastes are identified as hazardous or acutely hazardous, either through their inclusion on lists maintained by the Environmental Protection Agency (EPA) or by exhibiting a hazardous characteristic such as ignitability, corrosivity, reactivity, or toxicity. These wastes must be properly handled, stored, and disposed of in accordance with regulations.

The What and Why of Hazardous Waste Management

What it is: The EPA administers and enforces the Standards Applicable to Generators of Hazardous Waste found at 40 CFR 262. To ensure compliance, organizations must analyze all of their waste streams and determine if, how, and where they generate nonhazardous, hazardous, or acutely hazardous waste as defined by EPA lists. It’s a painstaking process, so many companies choose to work with consultants or waste management partners to supplement the efforts of their EHS teams.

Why it matters: Hazardous waste encompasses numerous materials, from toxic chemicals to wastewater sludge to manufacturing byproducts. These wastes pose potentially significant threats to human health and the environment. Through proper handling, storage, and disposal, organizations reduce the risk of:

• Employee injury or illness;

• Incidents that cause damage to property and machinery;

• Releasing environmental pollutants;

• Financial consequences of citations, fines, penalties, and lost productivity; and

• Reputational costs of noncompliance.

Steps for an Effective Hazardous Waste Inspection

The following items can be organized into a hazardous waste inspection checklist and should allow space for commentary where dates, quantities, descriptions of corrective action, or other notes may be necessary.

Waste identification and generator status

• Have all hazardous wastes been identified and monthly accumulations quantified in kilograms (kg)? Note that the EPA allows the weight of the container itself to be backed out of this total.

• Have your operations expanded or contracted in a way that may change monthly accumulations and generator status as outlined below?

• Very small quantity generator (VSQG): 100 kg or less of hazardous waste, or 1 kg or less of acute hazardous waste

• Small quantity generator (SQG): 100 kg, but less than 1000 kg, of hazardous waste, never generating more than 1 kg of acute hazardous waste

• Large quantity generator (LQG): 1,000 kg or more of hazardous waste or more than 1 kg of acute hazardous waste

Handling hazardous waste

• Are all workers who handle hazardous waste properly trained to do so with the required classroom, hands-on, and/or online training? Such training should include:

• Safe handling techniques

• Storage protocols

• Emergency response

Storing hazardous waste

• Is the hazardous waste clearly labeled and stored in an appropriate container or tank as specified by regulations?

• Are containers in central accumulation areas inspected at least weekly to look for any signs of leaking, corrosion, or other deterioration?

• Is your organization properly dating and tracking stored hazardous waste to ensure it does not exceed the accumulation time limit set for its generator status?

Disposing of hazardous waste

• Does your organization maintain a compliance calendarthat ensures timely shipment of hazardous waste to a Treatment, Storage, and Disposal Facility (TSDF)?

• When shipping to a TSDF, are all hazardous wastes compliant with regard to:

• Packaging;

• Labeling, marking, and/or placarding; and

• Shipping manifests?

• If your facility serves as its own TSDF, is it fully compliant with all relevant regulations?

Recordkeeping and reporting

• Are records supporting hazardous waste determinations for your organization kept on file for at least three years?

• Does your EHS compliance calendar ensure timely and compliant submission of hazardous waste biennial reports, if required?

Naturally, EHS managers should tailor their inspections to the specific hazardous materials and resulting wastes that are present in their organization’s operations. Software can help you create a comprehensive, thorough hazardous waste management program.

EHS Inspection Management Made Easier

EHS inspections rely on proper completion and management of checklists—and it can be a complex undertaking. Depending on the size and nature of their organization, EHS leaders need to ensure timeliness, consistency, and accuracy of inspections across departments and facilities.

That’s why EHS software is essential for managing your inspection program. An integrated software solution has the ability to standardize forms and processes, maintain compliance calendars, track closure of corrective actions, push reminders, and keep easily searchable records of results.

Perhaps most importantly, software can provide insights into the resulting inspection data via comprehensive analytics dashboards. Instead of simply filing away checklists and forgetting about them, software can illuminate where your EHS programs are succeeding and point out areas where additional training or other corrective actions may be necessary.

Software Solutions with an Eye for Safety

Inspections help EHS leaders maintain the vigilance necessary for safety and environmental compliance—and software solutions provide the power to manage it all effectively. Dakota Inspections allows you to create and share checklists tailor-made to your organization’s needs, plus track progress to guide completion of corrective actions.

Start your free trial today.