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RCRA Recordkeeping and Retention

The Resource Conservation and Recovery Act lays the foundations for cradle-to-grave management of hazardous waste. Generators play an important role in ensuring safe and effective disposal including proper record keeping and reporting. Both Large Quantity Generators (LQGs) and Small Quantity Generators (SQGs) are required to keep proper documentation to stay in compliance.

A Conditionally Exempt Small Quantity Generator (CESQG) is not required by RCRA to keep records however, as best practice it is suggested to keep certain documents for three years to provide evidence of their status. Executed, signed copies of the Hazardous Waste Manifest and Hazardous Waste Determination for all solid waste are documents a CESQG would benefit in keeping on file.

For SQGs and LQGs, regulations may vary in some respects but overlap on two points.

  1. Upon request, documentation must be presented to a USEPA or state agent.
  2. Records need to be kept for three years from the effective date of compliance.

The table below illustrates the start date of the 3-year period of record retention for LQGs and SQGs. The exemptions which apply to SQGs are highlighted in color.

RecordEffective Date
Properly Executed Uniform Hazardous Waste Manifest *Date waste was accepted by the initial transporter
Uniform Hazardous Waste Manifest Exception ReportsDue date of the report
Land Disposal Restriction Notification & CertificationsDate waste was last sent to onsite or offsite treatment storage or disposal
LDR Waste Analysis PlanDate waste was last sent to specified onsite treatment
Biennial ReportDue date of the report (March 1st)
Waste Analysis DataDate waste was last sent to onsite or offsite treatment storage or disposal
Process Knowledge Hazardous Waste DeterminationDate waste was last sent to onsite or offsite treatment storage or disposal
Weekly Inspection Record – ContainersDate of inspection
Daily Inspection Record – TanksDate of inspection
Facility Personnel TrainingCurrent employees until facility closure. Last day of employment for former employees
Emergency Responder AgreementsDate of agreement or refusal
Contingency PlanActivation date
Export ReportsDue date of the report (March 1st)
* Please note that Generators that have registered with e-Manifest may elect to use their e-Manifest account to store and retrieve their manifest copies.

It should be noted that state requirements may vary and although documentation may not be required by RCRA, each generator should check their state regulations as well.

If audited, it is helpful to be prepared and stay organized throughout the year. The core documents your EPA inspector will likely want to see should be kept in a common space, in the same electronic file for digital documents or in the same filing cabinet for hardcopies. This also helps in preparing the biennial report when you may need to reference documents or search for specific data.

Further explanation of these standards can be found in 40 CFR part 262 and part 268.

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