Regulator’s Top Ten Violations

1. Waste label not properly filled out.
2. Weekly inspection of Satellite Accumulation Area (SAA) or <90 Day Storage not up-to-date or missing.
3. Full container remaining in SAA for more than three days and/or more than one container per waste stream (type of waste).
4. Incompatible waste materials.
5. No impervious base (secondary container requirement). All waste containers must be stored in a compatible secondary container in order to contain spills.
6. Required annual training not documented (Hazardous Waste Training).
7. Open waste container or container not properly closed.
8. SAA not under control of staff generating waste and/or SAA not at or near the site of generation. Example, not across or down the hall from site of generation.
9. Spillage or leakage of waste (including contamination on the container).
10. Failure to determine waste as hazardous. Example, it is clearly waste but there is no waste label.

All above violations have contributed to substantial EPA fines at many colleges and universities in the New England area.

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