Recordkeeping

Businesses that generate dangerous waste are required to keep records about their waste. Your generator category determines the type of records and length of time you must keep them:

Medium quantity generators (MQGs) and large quantity generators (LQGs) must keep records, typically for five years.
Small quantity generators (SQGs) have less requirements but are encouraged to keep records in the same manner as MQGs and LQGs.

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What records do you need to keep?

The most common records required are grouped by generator category below. Additional records may be required depending on the type of dangerous waste or dangerous waste activity at your facility. For example:

Guidance on recordkeeping is noted throughout the Dangerous Waste Regulations, but the following sections explain recordkeeping for small quantity generators (SQGs) in the most detail:

Record type	SQG Requirement	Length of time
Designation records: Proof of waste types Material Safety Data Sheets (MSDS) or Safety Data Sheets (SDS) Other documents that support generator knowledge.	Required	5 years
Bills of lading and other shipping receipts	Optional, but highly recommended. Note: Other regulations, such as Department of Transportation (DOT) retention and recordkeeping, may be required.	Optional; 5 years recommended
Notification of dangerous waste activities	Required if you have an EPA/State Identification (ID) number	5 years (unless available in TurboWaste, then paper records not required)
Dangerous waste annual reports	Required if you have an EPA/State Identification (ID) number	5 years (unless available in TurboWaste, then paper records not required)
Treatment by generator (TBG) log	Required if you treat waste on-site	5 years
Recycling logs	Required if you recycle waste on-site (e.g., on-site distillation).	5 years
Special waste disposal records	Required if managed under the special waste conditional exclusion	5 years
Episodic event records	Required for planned and unplanned episodic events	5 years
Disposal or laundry facility records that meet the conditional exclusions for solvent-contaminated wipes	Required if you manage solvent-contaminated wipes under one of the conditional exclusions	5 years
Discharge authorization or permit for dangerous waste discharged under the domestic sewage exclusion	Required if managing under this exclusion	5 years
Permit-by-rule (PBR) unit current permit AND original permit application	Required if you treat waste in a PBR unit	Ongoing
PBR waste analysis plan	Required if you treat waste in a PBR unit	Ongoing

Guidance on recordkeeping is noted throughout the Dangerous Waste Regulations, but the following sections explain recordkeeping for MQGs in the most detail:

Record type	MQG Requirement	Length of time
Designation records: Proof of waste types Test results Material Safety Data Sheets (MSDS) or Safety Data Sheets (SDS) Other documents that support generator knowledge.	Required	5 years
Uniform Hazardous Waste Manifests (UHWM)	Required	5 years
Exception reports	Required	5 years
Bills of lading, or other shipping receipts	Required for wastes that are not shipped on a Uniform Hazardous Waste Manifest (UHWM)	5 years
Land disposal restrictions (LDR) documents	Required	3 years
Notification of dangerous waste activities	Required if you have an EPA/State Identification (ID) number	5 years (unless available in TurboWaste, then paper records not required)
Dangerous waste annual reports	Required if you have an EPA/State Identification (ID) number	5 years (unless available in TurboWaste, then paper records not required)
General facility inspection logs	Required	5 years
Weekly inspection checklist for central accumulation areas	Required	5 years
Daily tank inspection logs for MQGs	Required	5 years
Assessment reports and certifications for tank systems	Required	5 years
Annual inspections of ignitable or reactive waste areas	Required if storing ignitable or reactive types of waste.	5 years
Dangerous waste emergency information	Required to be posted in all areas where dangerous waste is generated or stored.	Ongoing
Documentation of arrangements with local fire and other emergency responders	Required	5 years
Treatment-by-generator (TBG) logs showing date and amount of waste treated on-site	Required	5 years
Recycling logs	Required if you recycle waste on-site (e.g., on-site distillation).	5 years
Spill reports	Required	5 years
Special waste disposal records	Required if managed under the special waste conditional exclusion	5 years
Episodic event records	Required for planned and unplanned episodic events	5 years
Disposal or laundry facility records meeting the conditional exclusions for solvent-contaminated wipes	Required if you manage solvent-contaminated wipes under one of the conditional exclusions	5 years
Discharge authorization or permit for dangerous waste discharged under the domestic sewage exclusion	Required if managing under this exclusion	5 years
Permit-by-rule (PBR) unit current permit AND original permit application	Required if you treat waste in a PBR unit	Ongoing
PBR waste analysis plan	Required if you treat waste in a PBR unit	Ongoing

Guidance on recordkeeping is noted throughout the Dangerous Waste Regulations, but the following sections explain recordkeeping for LQGs in the most detail:

Record type	LQG Requirement	Length of time
Designation records: Proof of waste types Test results Material Safety Data Sheets (MSDS) or Safety Data Sheets (SDS) Other documents that support generator knowledge.	Required	5 years
Uniform Hazardous Waste Manifests (UHWM)	Required	5 years
Exception reports	Required	5 years
Bills of lading, or other shipping receipts	Required for wastes that are not shipped on a Uniform Hazardous Waste Manifest (UHWM)	5 years
Land disposal restrictions (LDR) documents	Required	3 years
Notification of dangerous waste activities	Required if you have an EPA/State Identification (ID) number	5 years (unless available in TurboWaste, then paper records not required)
Dangerous waste annual reports	Required if you have an EPA/State Identification (ID) number	5 years (unless available in TurboWaste, then paper records not required)
General facility inspection reports, logs, and schedule	Required	5 years
Weekly inspection checklist for central accumulation areas	Required	5 years
Annual inspections of ignitable or reactive waste areas	Required if storing ignitable or reactive types of waste.	5 years
Employee training plan and records	Required	Ongoing for current employees, and 3 years for former employees
Written contingency plan and quick reference guide	Required	5 years
Incident reports (15 day report)	Required if contingency plan was implemented	5 years
Spill reports	Required	5 years
Treatment-by-generator (TBG) logs showing date and amount of waste treated on-site	Required	5 years
Recycling logs	Required if you recycle waste on-site (e.g., on-site distillation).	5 years
Special waste disposal records	Required if managed under the special waste conditional exclusion	5 years
Daily tank inspection log for LQGs	Required	5 years
Assessment reports and certifications for tank systems	Required	5 years
LQG consolidation records	Required	5 years.
Disposal or laundry facility records meeting the conditional exclusions for solvent-contaminated wipes	Required if you manage solvent-contaminated wipes under one of the conditional exclusions	5 years
Discharge authorization or permit for dangerous waste discharged under the domestic sewage exclusion	Required if managing under this exclusion	5 years
Permit-by-rule (PBR) unit current permit AND original permit application	Required if you treat waste in a PBR unit	Ongoing
PBR waste analysis plan	Required if you treat waste in a PBR unit	Ongoing

Should you keep hard copy or digital records?

You can keep digital records as long as you can provide hard copies upon request. We do, however, highly recommend you keep a hard copy of the following items in the event of an emergency:

Written contingency plans.
Quick reference guides.

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Recordkeeping

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What records do you need to keep?

Should you keep hard copy or digital records?

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