Unind States
Environmental Pioiection
Of'-ce of
Solid Waste and
Pesoorse
&EPA
DIRECTIVE NUMBER: 9938.2
TITLE: RCRA Inspection Manual
APPROVAL DATE: July 24,1981
EFFECTIVE DATE: J"ly 24, 1981
ORIGINATING OFFICE: OWPE
® FINAL
D DRAFT
LEVEL OF DRAFT
O A — Signed by AA or OAA
D B — Srgned by Office Director
DC — Review & Comment
REFERENCE (other documents):
SWER OSWER OSWER
DIRECTIVE DIRECTIVE Dl
-------
United Slates
Environmental Pioiecuon
Agency
SOLO Waste and
Emergency Resoorse
vv EPA
DIRECTIVE NUMBER: 9938.2
TITLE: RCRA Inspection Manual
APPROVAL DATE: July 24,1981
EFFECTIVE DATE: July 24, 1981
ORIGINATING OFFICE: OWPE
E FINAL
D DRAFT
LEVEL OF DRAFT
DA — Signed by AA or OAA
D B — Signed by OHice Director
DC — Review & Comment
REFERENCE (other documents):
S WER OSWER OSWER
DIRECTIVE DIRECTIVE Dl
-------
6ER&
eS CnvlrOnfTleniai rTOifiCllOn AQCflCV
Washington. OC 20460
1 Directive Number
OSWER Directive Initiation Request 9938
.2
2. Originator Information
Name ol Contact Person
Tim Kasten
Mail Coce
WH-527
Office
OWPE/RED
"elephone Cooe
475-9360
3 Title
RCRA Inspection Manual
4 Summary of Direct:', e uncuce one! statement of purpose)
Provides guidance to RCRA inspectors on how to properly prepare for,
conduct, and report on Compliance Evaluation Inspections (CEI) at RCRA
generators and interim status treatment, storage, and disposal faciliti-
5 Keywords
RCRA, inspection, Compliance Evaluation Inspection, inspector.
6a Does This Directive Supersede Previous Directive^;?
b Does It Supplement Previous Directivefs)1
No
No
Yes What directive (number, title)
Yes What directive (number, We)
7 Draft Level
A - Signed by AA/DAA
B - Signed by Office Director
C - For Review & Comment
0 - In Development
B.
Document
to
be distributed
to
States by Headquarters?
Yes
-
This Request Meets OSWER Directives System Formal Standards.
9 Signature of Lead Office Directives Coordinator
10 Name ana Title of Approving Official
Dale
Date
EPA Form 1315-17 (Rev. 5-87) Previous editions are obsolete
OSWER OSWER OSWER 0
VE DIRECTIVE DIRECTIVE DIRECTIVE
-------
9958.2
RCRA INSPECTION MANUAL
Submitted to:
Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
499 South Capitol Street, S.W.
Washington, D.C. 20460
Prepared by:
FRED C. HART ASSOCIATES, INC.
1110 Vermont Avenue, Northwest
Washington, O.C. 20005
July 24, 1981
-------
9938,2
LIST OF FIGURES
Figure Page
1. Industrial and Mutual Aid Emergency Contacts 11-16
2. Hazardous Waste Compatibility Chart 11-24
3. Required Submittals to the Regional Administrator V-10
4. EPA Guidance and Background Documents for Subtitle C V-ll
5. Sampling Plan Checklist V-14
6. Sampling Identification Tag V-30
7. Chain of Custody Record and Instructions V-32
8. Receipt for Samples V-36
S. Inspection Report Format VI-4
10. RCRA Site Identification Checklist VII-93
11. Generators. Checkiist , VII-94
12. Facilities Checklist VII-99
13. Landfills Checklist VII-105
14. Waste Piles Checklist VII-107
15. Surface Impoundments Checklist Vll-108
16. Incinerators Checklist V1I-110
17. Tanks Checklist VII-111
16. Land Treatment Checklist VII-114
19. Chemical, Physical, and Bloloplcal Treatment
Check! 1 st VII-117
20. Thermal Treatment Checklist VII-119
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9938. 2
LIST OF TABLES
TABLE
1. Sampling Points for Most Waste Receptacles V-I7
2. Methods of Preservation V-29
3. Regulatory Requirements, Inspection Procedures,
and Documentation VII-4
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9938.2
LIST OF TABLES
TftBLE Page
1. Sampling Points for Most Waste Receptacles V-17
2. Methods of Preservation V-29
3. Regulatory Requirements, Inspection Procedures,
and Documentation VI1-4
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9938.2
I. INTRODUCTION
A. OBJECTIVE OF THE ACT
The Resource Conservation and Recovery Act of 1976, which amends the
Solid Waste Disposal Act, was passed by Congress to "provide technical and
financial assistance for the development of management plans and facilities
for the recovery of energy and other resources from discarded materials and
for the safe disposal of discarded materials, and to regulate the management
of hazardous waste." Subtitle C of the Act addresses the latter Issue,
mandating the control of hazardous waste from Its initial generation to its
ultimate disposal. It specifically calls for standards of performance
applicable to generators and transporters and to the owners and operators of
hazardous waste treatment, storage, and disposal facilities.
The legislative authority to conduct inspections of hazardous waste
handling facilities is provided by section 3007(a) of RCRA. This section
defines the purpose and scope of a RCRA Inspection as well as specifying
certain guidelines which should direct the conduct of an Inspection.
Section 3007(a) authorizes access to facilities which handle hazardous
waste. Access 1s granted to "duly designated" officers, employees of the
EPA or representatives of the Environmental Protection Agency. Inspectors
are permitted "to have access to, and to-copy all records * Inspections
uy be conducted either for the purposes of regulation development or
7/24/81 1-1 RCRA INSPECTION MANUAL
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enforcement. Likewise, section 3007 identifies the scope of a RCRA inspec-
tion, giving inspectors authority to conduct sampling and check for coiripli-
ance with recordkeeping and labeling requirements.
Lastly, section 3007 sets forth certain guidelines governing the con-
duct of an inspection. . Those guidelines require the inspector to:
request access;
enter at reasonable times;
conduct inspections with reasonable promptness;
give s&mple receipts and, if requested, sample portions equal
in volume or weight to the portion retained;
furnish analytical results; and
make inspection results, unless found to be confidential,
available to the public.
Under the directive of the Act, EPA has promulgated regulations estab-
lishing a Federal hazardous waste management system. Regulations contained
in Parts 262 and 263 establish standards for generators and transporters of
hazardous wastes and Parts 264 and 265 are the first phase of EPA's require-
ments under Section 3004 of RCRA for owners and operators of facilities that
treat, store and dispose of wastes. The regulations under Part 265 estab-
lish requirements applicable during the interim status period, the period
after an owner or operator has applied for a permit but prior to final
disposition of the application. The Part 264 regulations establish the
standards which will be used to issue permits for hazardous waste treatment,
storage, and disposal facilities. Because the final Part 264 regulations
have not been promulgated only standards established In Parts 262, 263 and
265 will be addressed in this manual.
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9538. 2
B. ROLE OF INSPECTIONS IN THE ENFORCEMENT PROGRAM
The RCRA Enforcement Program encompasses both administrative and In-
spection systems whose purpose is to assure that the regulations are being
properly adhered to by hazardous waste handlers. The administrative pro-
cedures will involve screening, analysis, and subsequent enforcement re-
sponse to input into the enforcement system. The initial input generally
will be generated from the RCRA inspection system. Inspections will re-
present the most substantive input into the RCRA enforcement system and play
a major role in the success or failure of any subsequent enforcement
actions.
An inspection serves three enforcement functions. These are: (1) to
detect and document violations and discover imminent hazards; (2) to support
enforcement actions; and (3) to determine conformance with compliance and
other enforcement orders. Two overriding criteria must guide the conduct of
an inspection if the most beneficial results are to be achieved. First, the
technical integrity of the inspection must be correct—that is, the in-
spector must properly and thoroughly measure the parameters in question.
Second, legal requirements concerning the conduct of Inspections oust be
scrupulously adhered to in order that the results be admissible in an
enforcement proceeding. The achievement of both of these criteria 1s vital
to the development of a successful enforcement program. Failure to Beet
either criteria could seriously hinder or even invalidate the results of
this resource-intensive enforcement tool.
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C. PURPOSE OF THE MANUAL
The purpose of the RCRA Inspection Manual is to delineate the policy
and procedures to be used for inspections of hazardous waste generators,
transporters, and treatment, storage and disposal facilities regulated under
Subtitle C of RCRA. This inspection manual should be distinguished from the
imminent hazard field investigation manual. ' The primary focus of that
program is uncontrolled sites investigations under section 7003 of RCRA.
This manual addresses the entire spectrum of procedures and policy, as well
as focusing on more field-oriented aspects of RCRA compliance Inspections
during the Interim Status Period of the RCRA program. It will function as a
training text, a desk reference, and a field manual for inspector trainees,
authorized field inspectors, and legal personnel.
Training Manual. The manual serves as the main text for the RCRA
Inspector Training Program. Although this manual is primarily designed for
training EPA field staff, States planning to institute hazardous waste
programs may also use the manual in the orientation and training of their
inspectors.
Reference Manual. The manual should serve as a reference guide for
professional field staff in carrying out their responsibilities in field
surveillance, facility Inspection, and enforcement activities. It contains
the authorities, objectives, responsibilities, policies, and procedures
required by field staff to do their job.
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9938.2
Field Manual. Inspectors may choose to carry the manual in Us en-
tirety into the field or may remove only selected portions (e.g. sampling
chapter, safety chapter). The manual contains sample checklists that should
be used in inspections to supplement documentation in field notes and parti*
cularly to assure that all important inspection areas have been covered.
Checklists are of two kinds: (1) facilities checklist (covering
requirements that apply to all facilities), and (2) specific to facility
type (I.e., generators, landfills, wastepiles, surface Impoundments, Incin-
erators, tanks, land treatment, chemical, physical and biological treatment,
and thermal treatment). Inspectors should carry the facilities checklist,
plus specific checklists appropriate to the operations in the facility being
inspected. For example, a facility might contain an incinerator as well as
a landfill. In such a case, the facilities checklists as well as the Incin-
erator checklist and landfill checklist should be used. Report forms could
be used subsequent to the inspection to document overall inspection findings
or simply to serve as a prototype reporting format.
D. AUDIENCE OF THE MANUAL
The manual is designed as a guide for professional field staff whether
they are affiliated with Regional or State offices or with private contrac-
tors. In addition to Inspection personnel who will directly use the manual,
the manual 1s available to other EPA personnel and to Interested member* of
the general public. Including facility owners and operators, attorneys, etc.
Based on their experiences, users of the manual are encouraged to offer
7/24/81 1-5 RCRA INSPECTION MANUAL
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suggestions, revisions and constructive criticism to the developers of the
manual. This will help in making the necessary revisions that keep the
manual a useful working tool.
E. STRUCTURE OF THE MANUAL
The sections of the manual include Safety Considerations, Administra-
tive Procedures, Preparation for Inspection, Conducting the Inspection,
Post-Inspection Procedures, and Types of Facilities. The contents of each
section are fairly explicit. Section II describes safety precautions and
Sections III-VI delineate procedures for preparing, conducting, and report-
ing an inspection. These chapters are general in nature. Information
specific to facility types is contained in Section VII, Types of Facilities,
which contains a table identifying Subtitle C regulations to be addressed in
inspections as well as the appropriate inspection procedures and documenta-
tion. This section is based on the Phase I hazardous waste regulations
promulgated in the Federal Register on February 26 and May 19, 1980 and
subsequent amendments to the regulations. For those regulations and any
subsequent amendments to hazardous waste management facilities, only interim
status standards are addressed. Section VII also includes the series of
checklists to be used during Inspections.
F. UPDATING THE MANUAL
As changes, revisions, or deletions occur In the manual, revised pages
will be sent to all manual holders with an Inspection Manual transmlttal
notice. The notice will Identify and describe the new Information being
Issued.
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9938.2
Each page of the manual Is identified at the bottom with the name of
this manual and the date. At appropriate intervals, a checklist of current
pages will be issued to show each page number and its latest issuance date.
When a check list is received, manual holders should check the dates of the
pages in their manual and file the checklist at the front of the manual.
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II. SAFETY CONSIDERATIONS
9933,2
A. OBJECTIVES
The handling and sampling of hazardous waste always poses a certain
degree of hazard. The objective of this chapter is to assure the safety of
persons handling hazardous materials through the use of proper safety equip-
ment and proper working habits. The chapter includes material on: 1) the
responsibilities of inspectors with regard to safety; 2) types of exposure
to hazardous waste; 3) initial hazard assessment; 4) emergency treatment; 5)
long terit risks from exposure; 6) safety equipment; 7} decontamination and
disposal of protective clothing; 8) guidelines concerning the safe handling
of hazardous waste; and 9} an annotated list of references.
B. RESPONSIBILITY OF INSPECTOR
During on-site'inspections of any hazardous waste handling facility,
safety precautions are paramount to all other considerations because of the
extreme dangers posed by hazardous waste. Despite thorough preparation, an
Inspector may not have adequate knowledge of site conditions. It 1s Impos-
sible to anticipate every hazard that could arise. Therefore, the Inspector
should use common sense, judgment and experience. The Inspector should also
consult the Regional Safety Officer prior to the Inspection 1n order to
review potential hazards and safety precautions. In all considerations
related to safety, the Inspector Is responsible for:
7/24/81 II-l RCRA INSPECTION MANUAL
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knowing all safety guidance and practices;
using tne "buddy system" when necessary;
maintaining safety equipment in good condition and proper
working order;
using safety equipment in accordance with guidance received,
labeling instructions, and common sense;
refraining from activities that would create additional haz-
ards (e.g. smoking, eating, etc. in the hazardous waste
"area");
maintaining safety consciousness -- when in doubt, follow the
safest course of action; and
preventing loss of life, injury, or health hazard in the
investigation.
C. TYPES OF EXPOSURE TO HAZARDOUS WASTE
In order to assure the safety of all RCRA Inspectors, all means of
exposure to hazardous substances must be protected against and minimized.
The purpose of the following information is to provide some insight into the
manner by which harmful substances may enter the body. These are four basic
routes of entry: inhalation, skin absorption, ingestion, and eye contact.
1. Inhalation
Breathing a gas, vapor, mist, fumes or dust (chemicals nay be
trapped on particles) Is the most common accidental torn of
exposure and this route of entry 1s the most likely cause of
systemic Illness. The Inhalation hazard depends on a number
of factors: the chance that the chemical In use will leak
Into the air; the concentration present in the air; the
volatility of the chemical at ambient temperature; the In-
herent toxicity of the chemical; the length of time the
chemical 1s breathed; and physical properties such as parti-
cle size of the mist, fumes, or dust.
Breathing gases, vapors, mists, dust or fumes from certain
chemicals may affect the body in two distinct ways. First.
7/24/81 11-2 RCRA INSPECTION MANUAL
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9938.2
there may be effects on the lining of the air passages of the
nose, throat and lungs. This can result 1n irritation and
may cause burns. Second, there nay be absorption of the
chemical from the lungs to the blood stream. The blood
distributes the chemical throughout the body tissue causing a
systemic effect in which the chemical nay act as an asphyx-
iant, a fibrotic, or a carcinogen.
The inspector should take the following precautions in enter-
ing a site of unknown hazard and/or in sampling from contain-
ers of hazardous waste having an inhalation hazard:
a. Use self-contained breathing apparatus or appropriate
respirator. Select respirator based on assessment of
hazard (see p\ II- 13).
b. Sample only in well-ventilated areas.
2. Skin Absorption
Skin exposure to hazardous chemicals may result in skin irri-
tation or penetration. The most prevalent skin irritation is
dermatitis in which the chemicals do not enter the blood but
cause inflammation. Certain chemicals have the capacity to
penetrate the unbroken skin and are picked up by the blood
stream and distributed throughout the body. Skin penetration
is probably the second most common accidental means of entry
of chemicals into the body. A combination of gloves, boots,
hats, and coveralls should be worn to protect against skin
irritation and penetration. Although no clothing is abso-
lutely impermeable to chemical penetration, certain clothing
types provide adequate protection against the hazardous
materials encountered. These types will be discussed later.
'In addition to donning proper safety clothing and equipment,
the following precautions should be used in inspecting sites
which may contain materials hazardous by skin contact:
a. Insure that all skin areas which may be contacted are
protected during site work;
b. When taking samples, carefully wipe all residue off the
containers after filling them with the sample;
c. After completing the Inspection, use proper procedures
for removing contaminated clothing while still it the
site;
d. Contaminated rags and other disposable Items, such as
gloves, should be bagged for proper disposal, avoiding
skin contact (see Decontamination and Disposal of
Protective Clothing, Chapter 11.F.).
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3. Ingestion
Toxic amounts of hazardous waste may be carried to the mouth
by hand when drinking, eating, or smoking. Therefore, these
activites must never be carried on during inspections or
after inspections until decontamination procedures have been
completed. Furthermore, liquids 'must not be pipetted or
siphoned by mouth under any circumstances.
4. Eye Contact
The eyes may be harmed by chemicals in solid, liquid or vapor
form. Irritant effects vary in degree from mild to severe.
Most chemicals have the ability to injure the eye to some
degree through surface contact or absorption. The following
precautions to avoid eye injury should be taken upon entering
a site:
a. Wear chemical goggles or face shield (without side
perforations);
b. Do not rub eyes when sampling;
c. Never wear contact lenses when working In areas where
hazardous materials may be encountered. Contact lenses
cannot be worn with self-contained breathing apparatus
or respirators.
D. INITIAL HAZARD ASSESSMENT
In conducting inspections of permitted hazardous waste management
facilities or those facilities with interim status, assessing the potential
hazard of the particular site before entry nay not require extensive field
nonitoring. However, detailed hazard assessment procedures are outlined
below for those sites suspected of presenting a high level of risk so that
the Inspector nay enter the facility with the necessary protective clothing
and equipment.
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9938.2
In order to determine whether to enter a potentially hazardous field
site and to determine the appropriate level of protective equipment to be
worn when entering, the nature and extent of the hazard first must be
assessed. The following is a decision logic for this procedure:
1. Prior to on-site arrival, review all evidence of potential
exposure. The review should include any information availa-
ble concerning the site and the hazardous waste handled.
2. Review all available toxicological information including
texts, computer data via phone link-up (OHM-TADS), manuals
(CHRIS), etc. (see Other References in Section II-J).
3. After reviewing the available environmental and lexicological
information, choose protective clothing according to the
types and levels of waste material handled.
4. The appropriate levels of protection should be assessed
according to the levels of protection described and delin-
eated in Section E of this chapter:
Level A
Level A protection must be worn when the inspector makes a
reasonable determination that the highest available level of
both respiratory and skin (and eye) contact protection is
needed. It should be noted that while Level A provides
maximum available protection, it does not protect against all
possible hazards. Consideration of the heat stress that can
arise from wearing Level A protection should also enter into
the inspector's decision. (Confort is not a decision factor,
but heat stress will influence work rate, scheduling, and
other work practices.)
Level B
The inspector must select Level 8 protection when the highest
level of respiratory protection 1s needed, but hazardous
material exposure to the few unprotected areas of the body
.(i.e., the back of the neck) is unlikely with Level B pro*
tective clothing.
Level C
The Inspector My select Level C when the required level of
respiratory protection 1s known, or reasonably assumed to be,
not greater than the level of protection afforded by air
purifying respirators, and hazardous materials exposure to
the few unprotected areas of the body (I.e., the back of the
neck) 1s unlikely with Level C protective clothing. Level C
requires carrying an emergency escape respirator.
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II-5
RCRA INSPECTION MANUAL
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Level D
Level D 1s the basic work uniform. The inspector must not
work in civilian clothes.
If conditions requiring levels A or B are assessed to exist, the RCRA
inspector should seek the support and expertise of a trained emergency
response team and defer entry to that response team.
Before entering the site, the inspector should determine if there is
evidence of fire or explosive potential or high levels cf nuclear radiation
where protective equipment would not be adequate. In such cases, entry is
totally unadvisable. Determination of such risks should be undertaken using
field monitoring equipment for explosivity and radioactivity. Each of these
parameters is discussed below.
Normal background radioactivity is approximately .02 millireontgens
(mR/hr.) However, activity of 2 mR/hr is acceptable for the period of
exposure associated with a hazardous waste-site investigation. Detection of
levels of activity approaching 2 mR/hr are cause for a very careful survey
of the entire site. If levels greater than 2 mR/hr are encountered, the
advice of a competent radiation health physicist oust be sought before
continuing operations on the site. Therefore, entry should be halted.
If explosivity readings greater than 20% but less than SOX LEL (lower
explosivity limit) are detected, a very careful survey of the area, Includ-
ing ground, waist, and head level readings, nust be Bade. Readings approach-
ing or exceeding SOX LEL are cause for Immediate withdrawal of personnel and
notification of the fire department. Upon determining the lower explosivity
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9938-2,
sary to enable
limit, inspectors are then to take such actions as are necessary
safe resumption of the investigation. Subsequent procedures nay Include,
for example, obtaining assistance from a trained emergency response team if
levels exceed 50% LEL and/or donning appropriate protective equipment if
readings are greater than 20% LEL but less than 50% LEL.
Areas exhibiting high levels of chemical air contaminants should Also
be avoided. If extremely dangerous levels are suspected, the inspector
should not proceed with the inspection. If chemical exposure levels are
uncertain, air monitoring equipment such as an oxygen meter, colorimetric
gas detector, photionization detector, or portable gas chromatograph (or-
ganic vapor analyzer) nay be used to conduct an Initial hazard assessment.
The limitation and reliability of each of these instruments is highly speci-
fic and should be understood carefully by the Inspector. It 1s advisable to
acquire training in the use of each of three prior to field testing. Formal
training is absolutely necessary for effective use of the OVA.
The.-iaspecior may enter the site to conduct a site survey; if radio-
activity readings are below 2 mR/hr, explosivity reads 20% LEL or less, and
high levels of chemical exposure are not suspected. Upon entry, a systema-
tic survey of the entire site should be made including ground, waist, and
head level readings of explosivity and radioactivity. Chemical hazards
should also be characterized. If dangerous levels of any of these para-
meters are encountered (I.e.. 2 mR/hr, approaching SOX LEL, or positive
chemical hazard tests), the inspector should withdraw Immediately from the
site.
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E. SAFETY EQUIPMENT
For adequate protection against exposure to hazardous substances, the
inspector must have available first aid and safety equipment, protective
clothing, and respiratory protection.
1. Protective Equipment Selection Criteria
EPA has identified four levels of protective equipment (Levels A, B, C,
and 0) for use on hazardous waste sites. Each level is described below,
along with the criteria to be used in determining which level is appro-
priate.
Level A (requires assistance of a trained emergency response
team)
(1) Personal Protective Equipment
Open circuit, pressure-demand SCBA
Totally encapsulated suit
Gloves, inner (surgical type)
Boots, chemical protective, steel toed and shank
Booties, chemical protective
(2) Criteria
Sites known to contain hazards which
require the highest level of respiratory
protection (as stated above)
will cause Illness as a result of personal
exposure, and
as determined by the emergency response team
could result In txposure to any part of the
body.
Sites for which the emergency repsponse team Bakes
a reasonable determination that, based on the lack
of information to the contrary, the site may be de-
scribed as stated directly above.
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9938. 2
Level B (requires assistance of a trained emergency response
team).
(1) Personal protective equipment
Open circuit, pressure-demand SC8A
Chemical protective
Overalls and long sleeved jacket, or
Coveralls
Gloves, inner (surgical type)
Gloves, outer, chemical protective
Boots, chemical protective, steel toe and shank
Booties, chemical protective
(2) Criteria
Sites known to contain hazards which require the
highest level of respiratory protection as stated
above and
hazard which will cause illness as a result of
personal exposure, and
and hazard for which the emergency response
team makes a reasonable determination that
personal exposure to areas of the body not
covered by Level B protective clothing Is
unlikely.
Sites for which the emergency response team Bakes a
reasonable determination tat, based on the lack of
•information to the contrary, the site may be de-
scribed as stated above.
Level_C
(1) Personal Protective Equipment
Full face-piece air-purifying respirator
Emergency escape respirator (carried)
Chemical protective
Overalls and long sleeved jacket, or
Coveralls
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Gloves, inner (surgical type)
Gloves, outer, chemical protective
Boots, chemical protective, steel toe and shank
Booties, chemical protective
(2) Criteria
Sites known to contain hazards which
do not require level of respiratory protection
greater than the level afforded by air purify-
ing repsirators (nominal protection factor of
100 as stated above,
will cause illness as a result of personal
exposure, and
the inspector makes a reasonable determination
that personal exposure to areas of the body
not covered by Level C protective clothing is
unlikely.
Sites for which the Inspector makes a reasonable
determination that, based on the lack of informa-
tion to the contrary, the site may be described as
stated above.
LeyelJ)
(1) Personal Protective Equipment
Coveralls, cotton
Boots/shoes, safety
Safety glasses
Hard hat with optional faceshield
Air purifying respirator (readily available)
(2) Criteria
Sites where the inspector makes a reasonable deter-
mination that hazards due to exposure to hazardous
materials are unlikely.
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. - .
2. First Aid ancf Safety Equipment v '
First aid and general safety equipment should be carried on all site
visits by the inspectors for use when needed. All equipment should be
properly maintained and periodically tested. Inspectors should obtain
training in first aid as well as in the operation of all safety and monitor-
Ing equipment. The first aid and general safety equipment needed are as
follows:
first aid handbook (American National Red Cross);
first aid kit -- including compresses, gauze, triangular
bandages, gauze roller bandage, eye dressing packet, baking
soda (to neutralize acids), salt or other emetic;
fire extinguisher;
supply of clean water;
portable eyewash unit;
explosivity meter;
radiation detector;
radio communications, portable telephones or walkie talkies;
plastic bags for contaminated equipment and clothing;
soap or waterless hand cleaner and towels;
safety rope and harness;
oxygen bottles, valves, etc.; and
a list of emergency telephone numbers.
2. Personal Protective Equipment
a. Protective Clothing. Protective clothing Bust be worn by til
inspectors to prevent skin exposure at hazardous'waste handling facilities
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until sufficient data has been acquired in a hazard assessment to enable the
inspector to make an informed judgment regarding its'. need. Without clear-
indications that work can proceed safely without protective clothing, in-
spectors must wear chemical-resistant pants and jackets, neoprene boots,
protective gloves, hard hats or head cover, face shields or chemical safety
glasses. Once adequate protective clothing is chosen, Inspectors Bust also
note that alertness is a significant safety factor. Since protective cloth-
Ing is cumbersome, it hastens the on-set of fatigue and heat exhaustion, can
offset alertness, and limits stay-time.
Both disposable and reusable clothing are available. Both have advan-
tages and disadvantages. Presently available disposable.clothing is fra-
gile, easily torn, and especially vulnerable during cold weather. Disposa-
ble shoe covers that are furnished with this clothing are highly vulnerable
and are of very limited value on rough ground or in walking through snagging
objects. Reusable clothing (usually made of neoprene or butyl rubber) 1s
available in much sturdier fabric and generally 1s preferred. Its disadvan-
tage is Its need to be decontaminated on-site or to be carefully packaged
and shipped for later decontamination by a laboratory.
The following 1s a 11st of protective clothing to be worn as needed in
the field if any cutaneous hazard exists and/or 1f campling Is conducted:
chemical safety glasses (prescription If required), goggles
and/or face shield;
rubber soled, chemical protective, non-skid, seta!-toed shoes
or metal-toed rubber boots;
chemical protective, neoprene or butyl rubber gloves long
enough to protect the wrist and be worn under the sleeves and
7/24/61 11-12 RCRA INSPECTION MANUAL
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9938,2
taped to them to prevent wastes from running Into the gloves
from the sleeves or to cover the arm to the elbow. Surgical
gloves may foe worn when writing and handling bottles;
coveralls made of closely woven fabric which are spill re-
sistant. If they are not spill resistant, a chemical pro-
tective apron should be worn over them;
chemical protective pants with ankle tie to be worn over the
boot;
chemical protective, long-sleeved (blouse-type) jacket cap*
able of covering SCBA;
long rubber apron with sleeves;
OSHA-approved hard hat or head covering made of plastic with
a plastic sweatband since cloth or leather sweatbands are
hard to clean;
disposable shoe covers (to be worn with rubber-soled shoes);
and
interior coveralls and/or cooling vest.
Manufacturers should be consulted for chemical resistivity of various mater-
ials (i.e., PVC, neoprene/butyl rubber, etc.).
b. Respiratory Protection. Respiratory protection may be necessary
during inspections of those sites designated by the initial hazard assess-
ment as presenting potential risks. The selection of adequate respiratory
protection has been mentioned in Section II. 0, Initial Hazard Assessment,
but specifics are discussed here. Selection depends primarily on the type
of hazardous substances to be encountered and must be done in accordance
with 30 CFR Part 11 and provisions of the National Institute for Occupa-
tional Safety and Health.
Proper respirator use requires formal training and continued Main-
tenance of the equipment. 05HA regulations pertaining to respiratory pro-
7/24/81 11-13 RCRA INSPECTION MANUAL
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lection require a training program that encompasses user responsibilities,
training for proper use, and respirator maintenance.
In assessing adequate protection against exposure to inhalation of
hazardous substances, three kinds of respiratory protection devices must be
considered: (i) self-contained breathing apparatus; (ii) supplied air or
air line respirator; and, (iii) air purifying respirator. In situations
requiring either a self-contained breathing apparatus or a supplied air
device (Level A and Level B), RCRA inspectors should seek the support and
expertise of a trained field team and defer entry to that response team.
i. Self-Contained Breathing Apparatus. The positive pressure self-
contained breathing apparatus (SCBA) provides the most complete breathing
protection for periods of time based on the amount of breathing air supplied
and the breathing demand of the wearer. Normally protection 1s provided for
about twenty minutes.
SCBA will be used when:
Containers of unknown or known hazardous materials are being
opened.
When in enclosed spaces where hazardous materials are pre-
sent, such as abandoned waste chemical storage buildings or
man-holes which have received spilled chemicals.
When the Inspector judges that the concentration of hazardous
materials 1n the air Is greater than 10 tines the OSHA
Permlssable Exposure Level (PEL) (OSHA Regulations 29 CFR
1910.1000).
In the donning and use of SCBA, the following precautions should be
observed:
7/24/81 11-14 RCRA INSPECTION MANUAL
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9938.2
SCBAs must be NJOSH-approved.
SCBAs should provide positive pressure in the mask area.
SCBAs should provide a tight face seal; qualitative fit
testing is required although quantitative fit is not.
Users of SCBAs should obain formal hands-on training to
guarantee operator proficiency and equipment maintenance.
Users of SCBAs should follow the manufacturer's instructions
for the donning and use of the equipment In addition to
formal training.
ii. Supplied Air Device. The supplied sir device delivers breathing
air through a supply hose connected to the wearer's facepiece. Generally it
is used for long-term entry into a "hazardous" area, a situation normally to
be avoided.
iii. Air-Purifying Respirator. The air-purifying device removes
contaminants from the atmosphere to some degree and can be used only in
atmospheres containing sufficient oxygen to sustain life. (In open air this
should not be a problem.)
Specific concentration limitations exist for specific devices. The
chemical-cartridge respirator provides respiratory protection against cer-
tain gases and vapors in concentrations not in excess of that labelled on
the cartridge. It should only be used in an area where minimal concentra-
tions night occur and where SCBA has been determined unnecessary. An In-
spector should carry a respirator having an organic vapor protection car-
tridge or combination cartridges. The respirators should be donned tanedl-
ately upon experiencing breathing difficulty, diillness or other distress.
strong taste or smell, or on judging that precaution 1s 1n order. Once the
7/24/81 IMS RCRA INSPECTION MANUAL
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respirator has been donned, the Inspector should withdraw from the site and
re-evaluate whether or not to continue operations with added protective
equipment. The cartridge respirator should not be relied on for protection
from organic vapors for extended periods.
Air purifying respirators or cartridge respirators should be worn when:
Hazardous materials in the air are not greater than 10 times
the PEL, and have good warning properties.
The inspector judges that respirators are needed as a precau-
tion against generation of low levels of toxic substances in
air due to sampling, handling, decontaminating, or other
operations.
Extended periods of use on-site, which would cause the capa-
city of the cartridge to be exceeded, are not required.
Measurements have verified that at least 19.5X oxygen is
present.
Emergency escape respirators are carried by cartridge respi-
rator users. Escape respirator must be donned immediately
upon experiencing any warning property such as difficulty
breathing, dizziness, or other distress, strong taste or
smell. User must then leave the site.
In donning and using air purifying respirators, the inspector should
remember that:
Air purifying respirators provide less protection than SCBA
and supplied air devices.
Air purifying respirators must be NIOSH-approved.
Cartridges also must be NIOSH-approved and should be Hatched
to the respirator by the manufacturer.
Air purifying respirators will provide adequate protection
only if they have good face seals. A qualitative fit test 1s
recommended for each employee using these respirators.
Users of air purifying respirators should follow the manufac-
turer's instructions on the donning and use of the equipment.
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9938.2
Cartridges should be replaced when the user senses or smells
the vapor. If the contaminant of interest does not have
warning properties, the cartridge must not be used.
Cartridge respirators do not supply oxygen. They are of no
use In oxygen-deficient atmospheres.
F. EMERGENCY TREATMENT
Before entering a site, it is absolutely mandatory that the inspect-
or(s) knows the locations and emergency telephone numbers of the nearest
emergency medical facility, ambulance service, fire department, police
department, poison control centers and EPA Office contact (see Figure 1).
In case of any emergency, appropriate assistance should be called immedi-
ately and the appropriate emergency treatment conducted.
The purpose of emergency treatment is to obtain relief and to prevent
further damage until professional treatment is obtained. It is advisable
for all inspectors to obtain first aid training. First aid procedures for
contamination or poisoning by hazardous components consist of removing,
diluting or slowing the movement of the poison. Some knowledge of the haz-
ardous substance combined with prompt treatment is essential in reducing the
poison's concentration. Accidents such as a fall or heat ctroke could also
require emergency treatment. For these measures and other emergency Infor-
mation, consult an American Red Cross First Aid Textbook.
Depending on the type of exposure, the following emergency steps should
be taken:
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FIGURE 1
INDUSTRIAL AND MUTUAL AID EMERGENCY CONTACTS
Organization
Division
Hours
Telephone
Association of American
Railroads
CHEMTREC
Dow Chemical
Ou Pont
Monsanto
National Foam Center
Poison Control Center
EPA Emergency Response
U.S. Coast Guard
Emergency Response
Chemical Emergencies
Emergencies
Emergency Response
Safety Office
Emergency Response
Division of Environ-
Response, National
Response Center
24-hour (202) 293-4048
24-hour (800) 424-S300
24-hour (517) 636-4400
24-hour (302) 774-1000
24-hour (618) 271-5835
24-hour (215) 363-1400
24-hour Consult White
Pages of Local
Telephone
Directory Under
"Poison Control"
or National
Clearinghouse
for Poison
Control Centers
Directory
(U.S.H.E.W.)
24-hour (201) 321-6660'
24-hour (800)424-8802
7/24/81
11-18
RCRA INSPECTION MANUAL
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9938.2
1. Inhalation
a. If warning signals are apparent, the victim should leave
the contaminated air space immediately.
b. If unconscious, the victim should be pulled out of the
contaminated area immediately. Rescuers should make
sure they are wearing proper respiratory and protective
equipment before attempting the rescue.
c. If the victim is no longer breathing, mouth-to-mouth
resuscitation or some other form of artificial respira-
tion should be begun immediately, away from the contami-
nated area. The rescuer should avoid contaminating
himself.
2. Stein Exposure
a. The skin should be washed with copious amounts of soap
and water.
b. If clothing is contaminated, it should be removed Imme-
diately and the skin washed thoroughly with running
water.
c. If a shower is available, it should be used immediately
and clothes should be removed while showering. This
procedure may be life-saving as certain highly toxic
chemicals are rapidly absorbed through the skin.
d. All contaminated parts of the body, Including the hair,
should be thoroughly decontaminated. It may be neces-
sary to wash repeatedly.
e. Medical attention should be obtained as soon as possi-
ble.
3. Inqestion
a. Vomiting should be induced except when the substance
presents an aspiration hazard, such as from a petroleum
product, or when the substance 1s a strong acid or
alkali. To Induce vomiting, a tablespoon of salt or
powdered mustard in a glass of warn water or syrup of
Ipecac can be taken as an emetic.
b. Drinking plenty of water and placing a finger down the
throat may also be effective 1n inducing vomiting. The
treatment should be repeated until vonritus 1s clear.
c. Medical attention should be obtained immediately.
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4. Eye Contact
a. If a toxicant should get into the eyes, they should be
washed with plenty of water. The eye itself should be
held open, rotated, and flooded with water so that all
surfaces are washed thoroughly. Washing should be
continued for at least 15 minutes.
b. Medical attention should be obtained immediately.
G. LONG TERM RISK
Possibilities for long-term risk inevitably exist in the handling of
hazardous wastes. Although there are no defined measures for avoiding these
risks, handlers of hazardous waste should be warned of their dangers. As
defined in Section 3001 of Subtitle C, hazardous wastes are those that
exhibit ignitability, corrosivity, reactivity, or toxicity, are listed as
hazardous because of those characteristics or because of radioactivity,
infectiousness, phytotoxicity, teratogenicity, carcinogenicity, mutagenici-
ty, and bioaccumulative characteristics. Five of these characteristics
generally do not cause acute effects; therefore, exposure to such substances
can only be detected over long periods of tine. For this reason, long-term
monitoring (e.g., periodic physical examinations) of the physical well being
of all hazardous waste handlers is highly recommended. EPA Medical Monitor-
ing Program guidelines are included in Appendix I. RCRA Inspectors should
be medically examined annually.
H. DECONTAMINATION AND DISPOSAL OF PROTECTIVE CLOTHING
In leaving a contaminated site, appropriate procedures Bust be carried
out for decontamination and for safe packing of protective clothing, burial
7/24/81 11-20 RCRA INSPECTION MANUAL
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9938.2
or safe packing of disposable gear, and transfer of equipment, gear, and
samples from the "contaminated" area to the "clean" area. Decontamination
sequences will depend upon several variables (e.g., SCBA inside or outside
protective clothing) that must be worked out in advance and all requTred
equipment should be available before entry into a site. An optimal sequence
1s as follows:
1. Remove boots.
2. Remove exterior protective garment.
3. Remove respirator.
4. Remove disposable gloves.
5. Remove interior coveralls and cooling vest (if used).
Protective clothing should be decontaminated with soap and water at the
site, allowed to dry, folded or turned inside-out, placed in a plastic bag,
sealed, and if necessary decontaminated further off-site. Face shields,
goggles, respirators, rubber gloves (non-disposable), and rubber boots
should also be washed between uses. If decontamination cannot be done at
the site, the. protective clothing should be folded or turned inside-out,
placed in a locked container, and shipped back to the laboratory for decon-
tamination. All disposable items should be disposed of on-site. Disposable
sampling equipment (e.g. disposable glass tubes, spatulas, scoops) Is pre-
ferable to reusable equipment.
Suggested material and equipment for a personal decontamination station
Include:
a water spraying device (optional);
containers for rinse water and equipment drops;
7/24/81 11-21 RCRA INSPECTION MANUAL
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solvents (if shippable);
assortment of chemical decontaminants (e.g., N-Con spray);
brushes and detergent to aid in cleaning operations;
towels or Kimwipes;
soap, shampoo, etc.; and
enough plastic bags to double bag all disposable Hems.
I. SAFE HANDLING OF HAZARDOUS WASTES
The following general guidelines should be followed in handling haz-
ardous waste:
1. Know the limitations of all protective equipment (especially
respirators). Check self-contained breathing apparatus
before leaving for the field.
2. Determine what routes of exposure to avoid for the waste
being sampled and the proper sampling and protective equip-
ment to be utilized.
3. Before sampling any hazardous waste, read the label and
manifest for all containers and determine as well as possible
the identity of the substance to be sampled and the potential
for hazards. Be cautious: the label (if there is one) may
not accurately represent the contents.
4. Use only proper tools (e.g., hydraulic penetrating device,
non-sparking bung wrench) for opening containers, and be
careful when opening and closing them.
5. Open and sample hazardous wastes only 1n areas where spills
can be cleaned up easily and properly. Waste containers
should not be moved.
6. Keep samples well narked.
7. Do not use uouth to siphon, and do not put hands near mouth
and eyes.
8. Have readily available a supply of detergent soap, clean
water and waterless hand cleaner.
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9938.2
9. Have the phone numbers of the local hospital, doctors, or
poison control centers available (see Figure 1).
10. Transport and store samples in a sturdy container (e.g., ice
chest); procedures must comply with DOT regulations.
While checking for waste content, the inspector should also check for
potential incompatibility of wastes. Evidence of this condition night be
exhibited as generated heat, fire, gas, an explosion, violent polymeriza-
tion, or solubilization of toxic substances. Hazardous waste compatibility
can be checked by using the chart contained in "A Method for Determining
Hazardous Waste Compatibility" by H.K. Hatayama et al. (see Figure 2). It
is advisable to carry the compatibility manual along on field inspections.
J. OTHER REFERENCES
The following is an annotated list of additional references organized
under three headings: (1) General Safety Manuals; (2) Chemical Indexes; and
(3) Handling of Toxic and Hazardous Substances.
1. Hazardous Waste Site Investigations
"NEIC Enforcement Considerations for Evaluations of Uncontrolled Haz-
ardous Waste Disposal Sites by Contractors," U.S. EPA, Office of En-
forcement, April 1980. Contains procedures and precautions for con-
ducting imminent hazard Investigations.
"Safety Manual for Hazardous Waste Site Investigations," U.S. EPA,
Office of Enforcement, Draft September 1979. Provides basis for organ-
ization safety plans and programs, and supplements existing safety
manuals with elements necessary to safely conduct hazardous waste site
Investigations and handle samples resulting from such Inspections.
"Hazardous Waste Site Investigations and Environmental Spill
Responses - Chapter 9" U.S. EPA, Office of Occupational Health and
Safety, August 1980. Establishes policy, responsibilities and proce-
dures for the conduct of Agency occupational health and safety program
for hazardous waste site investigations and environmental spill re-
sponses.
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00
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9938.2
2. General Safety Manuals
"American Red Cross First Aid Textbook," American National Red Cross,
Doubleday and Company, Garden City, New York, (latest- edition). Basic
text of first aio training containing preventive measures and remedial
advice.
"Occupational Safety and Health for the Federal Employee," U.S. Depart-
ment of Labor, Occupational Safety and Health Administration, January
1, 1979. A booklet outlining Federal government policy concerning
occupational safety and health protection provided for government
employees.
3. Chemical Indexes
"Alphabetical Index Industrial Safety Data Sheets," National Safety
Council, 425 North Michigan Avenue, Chicago, Illinois 60611. Lists
bulletins available on characteristics of over 200 chemicals.
"Condensed Chemical Dictionary," Arthur and Elizabeth Rose, Reinhold
Publishing Corporation, New York. Contains useful information on
chemical materials including shipping instructions and safety regula-
tions.
"CHRIS, A Condensed Guide to Chemical Hazards," Department of Transpor-
tation, U.S. Coast Guard, October, 1978. Contains a directory of
chemical names and the following information for each: common syno-
nyms, appearance, and general response information outlining basic
preventive and precautionary actions to be taken.
"Fire Protection Guide of Hazardous Materials," National Fire Protec-
tion Association, 60 Batterymarch Street, Boston, Massachusetts 02110.
A complete volume on fire, explosion, and health characteristics of
many chemicals and materials. Combines five previous NFPA tests (49,
491K, 35A,.325M,_and 704M).
"Hygenic Guide Series," American Industrial Hygiene Association, Akron,
Ohio 44312, March, 1977. Contains an alphabetical list of chemicals
with the following information for each: hygenic standards, signifi-
cant properties, industrial hygiene practice, specific procedures for
safe handling, and literature references.
"Matheson Gas Data Book," The Matheson Company, Inc., East Rutherford,
New Jersey; Joliet, Illinois; Newark, California. Matheson of Canada,
Ltd., Whitby, Ontario, 1961. Contains information on handling, use,
and recommended controls for gases. Includes description, specifica-
tion, toxicity, first aid, precautions in handling and storage, con-
tainer construction materials, cylinder and valve description, safety
devices, recommended controls, shipping regulations, commercial prepar-
ation, chemical properties, and physical data.
"Merck Index," 9th edition, Merck & Co., Rahway, New Jersey, 1968.
7/24/81 11-25 RCRA INSPECTION MANUAL
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"OHM-TADS (Oil and Hazardous Materials •• Technical Assistance Data
System)," U.S. EPA, Oil and Special Materials Control Division, Office
of Water Program Operations. -An automated information retrieval file
designated to facilitate rapid- retrieval of information on over 1000
oil and hazardous substances. Includes a wide variety of physical,
chemical, biological, toxicological, and commercial data.
Handling of Toxic and Hazardous Substances
Chemical Manufacturers Association, 1825 Connecticut Avenue, N.V. ,
Washington, O.C. 20009. The CMA has many publications which give
complete information on health and fire hazards, handling, storage,
labeling, packaging, and transportation. A list of publications is
available.
"Handling Guide for Potentially Hazardous Commodities," ed. David
Baskin, Ph.D., Commodity bafety System of the Railway Systems and
Management Association. Contains the following relevant Information:
chemical synonym directory, medical digest, pollution control, refer-
ences, priority risk worksheet, and emergency equipment.
"NIOSH Pocket Guide to Chemical Hazards," National Institute for Occu-
pational Safety and Health/Occupational Safety and Health Administra-
tion, OHEW (NIOSH 78-210), September, 1978. Presents, in tabular form,
information and recommendations relating to permissible exposure
limits, chemical and physical properties, health hazard Information,
respiratory protection, and personal protection and sanitation prac-
tices for 380 specific chemicals for which there are Federal regula-
tions.
"Patty's Industrial Hygiene and Toxicology, 3rd Revised Ed., Volume I:
General Principles," ed. George D. Clayton and Florence E. Clayton,
John Wiley and Sons, New York, 1978. Twenty-seven authorities in their
respective fields discuss such facets of the profession as air pollu-
tion, agricultural hazards, odors, heat stress, fire and explosion
hazards, atmospheric contaminants, pulmonary effects of Inhaled dusts,
noise and conservation of hearing, and more. The book also includes
methods of evaluation of the various problems likely to be encountered,
samples of methods of recordkeeping, and hazard control methods.
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III. ADMINISTRATIVE PROCEDURES
A. WORK ETHICS
1. Professional Stature
Personnel are expected to perform their duties in a professional and
responsible manner. Personnel shall:
a. develop and report the facts of an investigation completely,
accurately, and objectively;
b. conduct themselves at all times in accordance with the regu-
lations in the EPA handbook Responsibilities and Conduct for
EPA Employees;
c. avoid, in the course of an investigation, any act or failure
to act which could be considered motivated by reason of
personal or private gain; and
d. make a continuing effort to improve their professional know-
ledge and technical skill in conducting hazardous waste
inspections.
2. Conflicts of Interest
A conflict of interest may exist whenever an EPA employee has a person-
al or private interest in a matter which is related to his official duties
and responsibilities. It is Important to avoid even the appearance of a
conflict of Interest because the appearance of a conflict damages the inte-
grity of the Agency and Us employees in the eyes of the public. All em-
ployees must, therefore, be constantly aware of situations which are, or
give the appearance of being, conflicts of Interest when dealing with others
Inside or outside the government. For a detailed discussion of the situa-
tions and/or activities which nay result 1n conflict of Interest, personnel
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are directed to the publication Responsibilities and Conduct for EPA Employ-
ees, which also can be found in the Federal Register (Vol. 38, No. 73),
April 17, 1973.
3". Attire
Good public relations and common sense require that personnel dress
appropriately for field inspections. When conducting an off-site recon-
naissance where hazards would be minimal, contact with the public will
occur; therefore, regional policy relative to proper attire should be fol-
lowed. On-site reconnaissance and inspections will require that personnel
be protected from unknown hazards or toxic materials. Required protective
clothing and breathing apparatus were described in Section II.
4. Public Relations
It is important that cooperation be obtained and good working relations
established when working with the public. This can best be accomplished by
using diplomacy, tact, and persuasion. Even a hostile person should be
treated with courtesy and respect. Personnel should not offer opinions
concerning any person, other regulatory agency, or nanufacturer or Industri-
al product. All Information acquired in the course of duty 1s for official
use only.
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5. Gifts. Gratuities. Favors, Luncheons, etc.
An EPA employee is forbidden to solicit or accept any gift, gratuity,
entertainment (including meals), favors, loans, or any other thing of mone-
tary value from any person, corporation, or group having a contractual or a
financial relationship with EPA, having an interest .that may be substanti-
ally affected by such employee's official actions, or conducting operations
regulated by EPA. Acceptance of food and refreshments of nominal value,
such as a luncheon during a plant tour where the arrangements are consistent
with the transaction of official business, is an exception to the above
stated general rule.
6. Attended B-iberv
Money in varying amounts may be offered by persons whose activities are
being investigated. Offers are usually made by people unfamiliar with EPA
rules and regulations. Other bribes nay be blatant attempts to whitewash a
serious violation or condition or to cause the withholding of damaging
information or observations. Personnel shall:
a. ask "What is this for?" if offered something of value;
b. explain politely, if the offer is repeated, that both parties
to such transactions nay be guilty of violating Federal
statutes;
c. not accept money or goods of any kind; and
d. Immediately report the Incident 1n detail to their supervi-
sor.
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B. DISCLOSURE OP OFFICIAL INFORMATION
1. Requests for information
a. EPA Policy. EPA has an "open-door" policy on releasing informa-
tion to the public. It aims to make information about EPA and its work
available, freely and equally, to all interested individuals, groups, and
organizations. This policy, however, does not extend to information relat-
ing to enforcement investigations, including the suspicion of a violation,
or to evidence. When such information is requested, personnel should im-
mediately notify their supervisor and/or legal counsel.
b. Media Contacts. Inspectors should cooperate with representatives
of the press, other communications media, and interested groups. In cases
when an inspection team is present, one member should be designated as the
spokesperson. Information concerning the Agency's responsibility for in-
spections and investigative activities can be given. Questions concerning
investigation of alleged violations and enforcement policy should be refer-
red to the Regional Enforcement Director for response. In all contacts with
the media, the inspector should be cautious about making careless state-
ments.
2. Confidential Information
All confidential Information received shall be narked as such and
placed in a locked filing cabinet or safe.
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9938.2
a. Only personnel authorized by the Regional Admini-
strator, Division Director, or Branch Chief shall
be allowed access to the file.
b. Copies should not be made of information marked
"Confidential" unless authorized in writing by the
Regional Administrator, Division Director, or
Branch Chief.
Requests for access to confidential information by any member of the
public, or by a State, local, or Federal agency shall be handled according
to the procedure contained in the Freedom of Information Act regulations (40
CFR 2). All such requests shall be referred to the responsible regional
organization unit.
RCRA confidential claims are not to be confused with TSCA confidential
claims which require specific administrative procedures. TSCA confidential
information procedures are contained in 40 CFR 2 (§2.306).
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IV. PREPARATION FOR INSPECTION
In this chapter, the manual addresses preparation for inspections.
Included in this chapter are sections on objectives of inspections, inspec-
tor responsibilities for preparation, administrative preparation, notifica-
tion, and inspection equipment.
A. OBJECTIVES
The primary objectives of preparation for inspection are:
to obtain and review all Agency information essential to
conducting an effective inspection;
to permit completion .of the scheduled number of inspections
in a timely manner;
to minimize inconvenience to facility owners and operators by
not requiring them either to explain or produce information
which is already in the hands of the regulatory agency.
B. RESPONSIBILITY OF THE INSPECTOR
Inspectors are responsible for:
knowledge of permit conditions, compliance file, monitoring
requirements, etc., before on-site visits;
knowledge of applicable EPA policies and procedures;
knowledge of what the najor requirements of environmental
legislation other than RCRA;
Inspection scheduling;
adequate pre-inspection planning;
•
checking to see that a "Letter of Notification" of Inspection
has been sent to the facility if appropriate (not required by
RCRA but nay be useful in certain situations).
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C. ADMINISTRATIVE PREPARATION 7 7 JO. 2
In preparing to conduct a proper RCRA enforcement Inspection, the
inspector should become familiar with certain materials pertaining to the
particular site to be inspected. During Interim Status inspections, the
inspector's main source of information will be the facility compliance
files. At this time, the file will contain at least a) the notification
form; b) Part A of the permit application, consisting of Forms 1 and 3 (not
required for generators or transporters); c) possibly Part B of the permit
application; and d) reports and notices required by Parts 262, 263 and 265
of the regulations. In addition to the initial information mandated by the
Interim Status Standards, the inspector should seek preparation materials
listed below which are required by permit applications and/or the regula-
tions. As treatment, storage, and disposal facilities become permitted
under RCRA, the permits will provide a major portion of the background
material for conducting compliance inspections of these facilities. In the
case of generators and transporters, who are not required to have RCRA
permits, the list of preparation materials would omit RCRA permits, but
should include most other items listed below.
Generally, the preparation materials should Include:
1. a listing and copies of the RCRA and applicable state permits
as well as TSCA, NPOES, CAA, and UIC requirements applicable
to the facility;
2. a sketch or a copy of the survey nap (U.S.G.S.) showing the
waste facility location and environmental and geographical
features;
3. air photos with a scale of 1" - 100";
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9938,-2
4. a summary of names, titles, locations and phone numbers of
the responsible persons (operators, municipal or Industrial
officials) involved with the facility's hazardous waste
program. This information will be contained in the ADP
(Automatic Data Processing) system to be developed;
5. a flow chart or design features of the present and planned
facilities (if appropriate, Include industrial production
processes);
6. inspection reports from previous inspections (State and/or
Region), containing the compliance history of the site; and
any other recent correspondence and/or regulatory action,
noting the status of requested actions and/or compliance with
enforcement actions;
7. a letter of notification of inspection to the facility and
the response to the letter (if applicable);
8. annual and other reports submitted by the facility including
most recent monitoring reports.
9. previous EPA studies, consultant's reports, and laboratory
reports describing non-routine analyses; and
10. citizen's complaints filed against the site;
Because a summary of the information will be needed for future inspec-
tions, a "compliance file" should be prepared for each RCRA generator,
transporter, or permittee. Inspectors should take copies of the files with
them on inspections to assure them that needed information for timely com-
pletion of an inspection is readily available. However, compliance files
should not be shown to facility personnel under any circumstances. Later,
the original office file can be updated for the next Inspection.
In addition to reviewing documents, the Inspector should prepare a
sampling plan If sampling 1s to be done. (See Section V.E. below concerning
sampling plans.)
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D, NOTIFICATION QC"?Q 0
————— J 7 •J >*i f £,
Notifying a facility prior to an Inspection may or may not be carried
out depending on the circumstances and specific Regional decisions. In
certain cases where illegal discharges or dumping are suspected, prior
notification may be not appropriate. Conversely, in cases where specific
facility personnel must be spoken with, pre-notification would be appropri-
ate.
Methods of notification vary with the inspection purpose. Alternate
methods include the following: (1) an annual notification letter can be
sent out establishing the requirement for inspections but not specifying a
date; (2) a letter can be sent a month in advance notifying that an inspec-
tion will be conducted within a month; (3) in cases where the inspector
wishes to assure that certain personnel are present, he/she can phone In
advance and schedule specific appointments; or (4) the inspector may want to
arrive on-site unannounced to prevent the owner/operator from making any
last-minute changes to the site conditions. The first two methods of ad-
vance notification can be used in conjunction with either methods (3) or (4)
("phone call" or "surprise entry") or not used at all. The third altern-
ative might be used prior to Inspections in which records are to be checked
or certain comprehensive sampling 1s to be done. The last alternative
("surprise entry") 1s nost useful 1n cases where violations are suspected or
"cover-up" Is anticipated.
Information that nay be conveyed by the Inspector during notification
should consist of the Inspector's name and what organization or agency the
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inspector is affiliated with, the purpose of the inspection and the authori-
ty under which the inspection is to be conducted, the procedures of the
inspection, where it is to be conducted, and with whom the inspector needs
to confer. Information that should be obtained by the inspector should
include safety equipment requirements and, if appropriate, appointment
times.
E. INSPECTION EQUIPMENT
Depending on the facilities to be inspected, equipment should consist
of some or all of the following items:
Credentials;
Safety equipment (see Chapter II on Safety Considerations);
Copy of the facility's compliance file and monitoring schedule;
Camera (35mm, Polaroid);
Pocket tape recorder (for recording field notes);
Pocket calculator;
Tape measure (engineer's tape — 100 ft.);
Checklists (see Chapter VII);
Sampling equipment (see Sampling, Chapter V);
Documentation equipment (see Sampling, Chapter V);
-Level;
Range finder/Optical tape measure;
Compass;
Stopwatch;
Wind meter or Admiral Beauford Wind Scale;
Square; and
Tools.
It should be noted that this Is a basic 11st of equipment that nay be
required by the Inspector. However, it 1s recognized that all of the equip-
ment nay not be needed on any given Inspection. Some of the listed Items
are applicable to compliance evaluation Inspections 1n other programs and
should be carried to aid in multi-media Inspections.
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V. CONDUCTING THE INSPECTION
The objectives of this chapter are to lay out the inspection procedures
that apply to all types of regulated facilities, i.e., generators, trans-
porters, and treatment, storage and disposal facilities. These procedures
include the following:
1. scope of inspection;
2. entry into a facility;
3. pre-inspection discussion;
4. general procedures;
5. sampling;
6. quality assurance;
7. chain of custody procedures; and
8. documentation.
A. SCOPE OP INSPECTION
Inspection procedures will be determined in part by the scope of the
Inspection. The enforcement program categorizes inspections as being either
compliance evaluation inspections or compliance sampling Inspections. In an
attempt to further categorize varying scopes, the following types have been
Identified:
1. record review — an examination of facility records of tests
and analyses performed, self-monitoring conducted, sampling
performed, amounts and types of waste handled, nanlfests for
wastes transported from or to the site, etc. The «a1n pur-
pose is to determine compliance with the Agency's recordkeep-
ing and reporting requirements. The record review also will
Indicate evidence of Incompatibility of wastes.
2. cursory Inspection — a visual Inspection documented briefly
(grab samples might be taken). This is a possible nechanism
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9933.2
for flagging violations under other programs as well as under
RCRA, or for dealing with a specific aspect for a restraining
oroer.
3. preliminary survey •• an initial visual inspection. During
the inspection sampling needs and locations may be identified
and a general characterization of the site may"Be determined.
4. comprehensive inspection — a thorough visual and sampling
inspection. This inspection often is preceded by a prelimi-
nary survey.
5. sampling inspection — an inspection consisting only of
talcing samples. This inspection may be triggered by a cur-
sory inspection or preliminary survey in response to indica-
tions of potential violations. It 1s used mostly for en-
forcement purposes (i.e., case development).
Note that the aforementioned categories are by no means rigid. There
are variations under each type as well as combinations of them. They have
been named merely for descriptive purposes. It is up to the Enforcement
Division to determine how extensive or detailed the inspection needs to be
for each case. Under the Enforcement program categories, compliance evalua-
tion inspections would include record reviews, cursory inspections, and
preliminary surveys, and compliance sampling inspections would Include
comprehensive inspections and sampling inspections. If the inspection is
conducted under a warrant, the inspection scope will be limited to the
restrictions of the warrant.
B. EKTRY INTO A FACILITY
The appropriate tine of entry should be determined by the Inspector.
All Inspections should be conducted at reasonable tines or during noraal
working hours. Inspections which cannot be completed before the normal
close of business for the facility will be continued on the next business
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9933.2
day unless the time required for completion is so short that the management
does not object to working past normal closing time. If the facility runs
continuously or the management normally departs before operations Stop, the
Inspection may continue at the Inspector's discretion. However, the in-
spection should be completed In a timely manner.
Upon arrival at a company or facility, an Inspector should Introduce
himself/herself as an EPA inspector and present proper EPA credentials to
the owner, operator, or agent In charge whether or not Identification 1s
requested. He/she should allow the person to whom credentials are presented
the opportunity to closely scrutinize the credentials since they Indicate
that the holder Is a lawful representative of the Administrator of the
Environmental Protection Agency and authorize performance of Inspections
under RCRA and all other applicable statutes. The Inspector should then
document the entry In his/her logbook and note the date, time, and name and
title of the facility personnel encountered.
The Inspector should be aware that consent to the inspection may be
withdrawn at any time. However, any segment of the inspection completed
before the withdrawal of consent remains valid. Withdrawal of consent is
the equivalent of a refused entry. Therefore, a warrant may be secured to
complete the inspection (see procedures below.)
Consent to site entry is not required for an inspection to observe and
report on things in plain view, (i.e., that a member of the public could be
in a position to observe). This includes observations Mde while on private
property in areas not closed to the public (e.g., natters observed while the
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9938.2
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1. Use of a Warrant to Gain Entry
a. If there is a high probability that entry will be re-
fused even with a warrant or where there are threats of
violence, the inspector should be accompanied by a U.S.
Marshall.
b. The Inspector should never himself/herself attempt to
make any forceful entry of the establishment.
c. If entry is refused to ar\ inspector holding a warrant
but not accompanied by a U.S. Marshall, the inspector
should leave the establishment and inform the Enforce*
ment Division Attorney.
2. Conducting The Inspection
a. The inspection must be conducted strictly in accordance
with the warrant. If the warrant restricts the inspec-
tion to certain areas of the premises or to certain
records, those restrictions must be adhered to.
b. If sampling is authorized, all procedures must be care-
fully followed including presentation of receipts for
all samples taken. The facility should also be informed
of its right to retain a portion of the samples obtained
by the inspector.
c. If records or property are authorized to be taken, the
inspector must provide receipts and maintain an inven-
tory of all items removed from the premises.
Inspectors should consult NEIC's procedures for further guidance (see
Appendix II).
C. PRE-INSPECTION DISCUSSION
During the initial Inspection, the inspector should, If necessary,
discuss the provisions of the Act and, if requested, furnish a copy of the
Act and appropriate regulations. The Inspector then should outline the
objectives of the inspection and the order in which various aspects of the
facility's operations will be examined. If duties regarding hazardous waste
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9958.2
handling, storage, recordkeeping, or disposal have been delegated to various
key facility personnel, the inspector can suggest a schedule for meeting
with those responsible persons if a meeting has not been established al-
ready. A well-planned schedule can eliminate wasted time in waiting for
records to be gathered, key facility personnel to become available, and
Intermittent facility operations to be started. During a compliance inspec-
tion, it would be beneficial to have a facility representative accompany the
inspection team to describe to them the plant and its principal operating
characteristics and to answer their questions.
The plant manager and facility officials should also be informed of
their right to request and receive immediately duplicates of any samples
(gaseous, liquid or solid) collected for laboratory analysis during the
inspection, and copies of analysts results later (if an enforcement case is
not pending or being pursued). By establishing a mood of cooperation be-
tween the inspection team and facility officials, inspectors will be able to
accomplish inspection activities BOre easily.
All inspections must be conducted in light of the Barlow's decision.
An understanding of the Implications of this decision on inspection activi-
ties is crucial for their proper evaluation. In the Barlow's decision.
Involving an OSHA Inspector who was denied entry to a facility, the court
held the following:
1. an Inspector 1s not entitled to enter non-public positions of
a work site without either
the consent of the owner/operator, or
a warrant;
7/24/61 V-6 RCRA INSPECTION MANUAL
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2. the owner is protected against penalty or punishment for
insisting on a warrrant;
3. the decision does not pertain to public portions of the
facility.
4. consent of the owner/operator to allow the inspection can be
withdrawn at any time.
D. RECORD REVIEW
Section 3007 of the Act states that the regulated community shall
"furnish" or "permit" inspectors "to have access to and to copy all records
relating to such wastes" (i.e., hazardous wastes covered by Subtitle C).
The regulated community, comprised of hazardous waste generators, trans-
porters, and facilities, must address administrative requirements for mani-
fests, recordkeeping, and reporting; and hazardous waste facilities must
comply with technical requirements mandating plans for waste analysis,
training, contingency procedures, ground-water monitoring and closure.
During the Interim Status period, RCRA Inspectors are responsible for
reviewing all recordkeeping as required by §122.4, §122.7, §263.22, and
§265.74. Although most of the records are not required to be kept in a
standard format, inspectors should inspect for 1) the presence of the re-
quired records or plans; 2) dates of the documents (whether they are being
kept up-to-date and/or maintained for the required period); and 3) any sus-
pected falsification of data.
The regulatory requirements under §122, §262, §263, and §265 mandate
that the following records be maintained by the regulated parties:
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Permit Applicants
122.4 Data used to complete permit applications
122.7 Records of all monitoring information
122.7 Copies of all reports
Annual report (265.75)
Unmanifested waste report (265.76)
Additional reports (265.77)
Releases, fires, explosions
Groimdwater contamination
Facility closure
9938.2
Generators
§262.24 •
•
•
§262.40 •
Transporters
§263.22 -
Job Titles and Personnel Records
Agreements with Local Authorities
Contingency Plan
Manifests
Annual Reports
Exception Reports
Waste Analysis and Test Results (performed in
accordance with 262.11).
Manifests
Shipping Papers (Bulk shipment by rail or
water)
Manifests for Foreign Shipments
Treatment, Storage, and Disposal Facilities
a. General Facility Standards
Waste Analysis Plan
Inspection Schedule
Job Titles and Personnel Records
Contingency Plan
265.13
265.15
265.16
265.51,
53
265.71, Manifest System (Records of Manifests)
72
265.73 Operating Record
265.93 Outline of Groundwater Monitoring Plan
265.94 Groundwater Monitoring Record
265.112 Closure Plan
265.118 Post-Closure Plan
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V-8
RCRA INSPECTION MANUAL
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b. Facility Specfic Standards
265.279 Land Treatment
specific operating record requirements
specific requirments for closure plan
265.309 Landfills
specific operating record requirements
records for contents and organization of
cells
specific reuirements for clo.sure plan.
c. Required submittals to the Regional Administrator. (See
Figure 3).
While performing a record review in accordance with the respective
generator, transporter and interim status regulations, the inspector may
encounter problems in accurately interpreting the regulations. Therefore,
the Agenncy has made available a number of guidance documents and lists of
available background documents that will aid both the inspector and the
regulated community in properly complying with the recordkeeping require-
ments of Subtitle C. Figure 4 shows an annotated list of these references.
E. GENERAL PROCEDURES
Step-by-step inspection procedures will vary with the type of facility
being inspected. Procedures will follow a series of checkpoints outlined in
Chapter VII. General procedures for all types of facilities are outlined in
the general Inspection checklist in Chapter VII. The remaining procedures
consist of Inspecting Items listed on the checklist specific to the type of
facility. Therefore, each type of facility Is dealt with Individually in
Chapter VII, where each of the applicable regulations and specific check-
lists are delineated.
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FIGURE 3
9938.2
REQUIRED SUSMITTALS TO THE REGIONAL ADMINISTRATOR
Section 265.11
Section 265.12
Section 265.56
Section 265.72
Section 265.74
Section 265.75
Section 265.76
Section 265.93
Section 265.94
Section 265.115
7/24/81
EPA identification number.
Notice of date of arrival of hazardous waste from a
foreign source.
In cases of releases, fires, or explosions, noti-
fication by emergency coordinator that an affected
area is adequately cleaned up before operations are
resumed.
Written report by emergency coordinator on emer-
gency incident within 15 days of incident.
Manifest discrepancy report within 15 days of
receipt of waste.
Upon closure, copy of records of waste disposal
locations ana quantities.
Annual report.
Unmanifested waste report within 15 days of receipt
of waste.
In cases of a confirmation of analyses indicating
significant increase (or pH decrease), a written
notice that the facility nay be affecting ground-
water quality, within seven days of date of such
confirnaion.
Within 15 days after above notification, specific
plan for a groundwater quality assessment program
at the facility.
After determination of the above groundwater qual-
ity assessment, written report containing an assess-
ment of groundwater quality and/or Indicating a
re-instatement of the Indicator evaluation program.
Recordkeeping and reporting: groundwater monitor-
Ing Information as specified in this section.
Annual reports of Section 265.75 contain results of
groundwater quality assessment program.
Certification of closure.
V-10
RCRA INSPECTION MANUAL
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FIGURE 4
EPA Guidance and Background Documents for Subtitle C
1. Regional Guidance Manual for Selected Interim Status Require-
ments (Draft). Office of Solid Waste, U.S. EPA, September
22, I960.
Section on Plans and Recordkeeping including sample waste
analysis plan, contingency plan, groundwater assessment
plans, and operating record.
2. Hazardous Waste Management - A Guide to the Regulations.
Office of Solid Waste, U.S. EPA, 1980.
A guide to hazardous waste regulations promulgated on
February 26 and May 19, 1980. Consolidates 300 commonly
asked questions and answers concerning the application of the
regulations to specific situations.
3. Draft Guidance for Subpart G of the Interim Status Standards
for Owners and Operators of Hazardous Waste Treatment, Stor-
age and Disopsal Facilities, (Draft), Prepared by Inter-
national Research and Technology Corporation for U.S. EPA,
October 16, 1980.
Covers closure and post-closure plans. Presents outlines for
sample plans.
4. Background Documents. Eighteen background documents devel-
oped by the Agency to explain and respond to comments on the
Phase I rules, each corresponding to a Section or Subpart.
List of background documents is as follows:
a. Purpose, Scope, and Applicability (Including general
issues concerning Interim Status Standards)
b. General Waste Analysis Requirements
c. Security
d. General Inspection Requirements
e. Personnel Training
f. Preparedness and Prevention, Contingency Plans, and
Emergency Procedures
g. Manifest System, Recordkeeping, and Reporting
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ZQ 9
Figure 4 - Continued JO- «-
h. Interim Status Standards for Ground-Water Monitoring
i. Interim Status Standards fc- Closure and Post-Closure
Care
j. Interim Status Standards Financial Requirements
k. Interim Status Standards for Containers and Piles
1. Interim Status Standards for Tanks
m. Interim Status Standards for Surface Impoundments
n. Interim Status Standards for Land Treatment
o. Interim Status Standards for Landfills
p. Interim Status Standards for Incinerators
q. Interim Status Standards for Thermal Treatment
r. Interim Status Standards for Chemical, Physical, and
Biological Treatment.
These documents can be obtained from EPA Regional office
libraries, at EPA Headquarters library, or from Solid Waste
Information, U.S. EPA, 26 West St. Clair Street, Cincinnati,
Ohio 4525S.
5. Reference Manuals. A series of design and operation manuals
being prepared by the Agency to assist owners and operators
and facilities and regulatory officials. The following
manuals will be completed by the Agency:
a. Training
b. Ground-Water Monitoring
c. Air Monitoring
d. Financial Responsibility
e. Containers
f. Tanks
g. Surface Impoundments
h. waste Piles
1. Land Treatment
J. Landfill ing
k. Incineration
1. Thermal Treatment
m. Chemical, Physical, and
Biological Treatment.
These documents also will be available through Solid Waste
Information, U.S. EPA, 26 West St. Clair Street, Cincinnati,
Ohio 45268, or through EPA Regional libraries.
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F. SAMPLING
In general, sampling of hazardous waste requires the collection of
samples that are adequate In size and representative of the body of wastes.
Sampling situations vary widely. Therefore, no universal sampling procedure
can be recommended. Rather, several procedures will be outlined for samp-
ling different types of wastes In various states and receptacles. The in-
spector should consult with a Jaboratory prior to taking samples in order to
determine the adequate containerization and preservation techniques.
Sampling procedures require a plan of action to maximize safety of
sampling personnel, minimize sampling time and cost, reduce errors in sam-
pling, and protect the integrity of the samples after sampling. A sampling
plan should be prepared before entering a site. The following steps are
essential in this plan of action (see Figure 5 for a checklist to be used in
inspection preparation):
1. Research background information about the waste (composition.
form, concentration, etc.).
2. Determine equipment and procedural needs for safe sampling.
3. Consider proper locations for sampling.
A. Determine the volume of samples to be taken.
5. Determine the sampling equipment needed.
6. Review procedures for sample collection.
7. Review procedures for containing and handling samples.
8. Properly execute chain-of-custody procedures.
9. Identify necessary packaging, labeling, and shipping require-
ments, including the following:
a. Identify samples and protect from tampering (secure
evidence tape if available).
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FIGURE 5 5933' 2
Sampling Plan Checklist
1. Background research concerning waste
2. Identify safe sampling equipment
3. Identify safe sampling procedures:
a. proper location(s)
b. volume of samples
c. collection procedure
d. containment and handling
4. Review chain of custody procedures
5. Review packaging, labelling and shipping
requirements:
a. identify samples
b. protect from tampering
c. fill out field notebook
d. complete sample analysis request
sheet
e. complete receipt of sample form
6. Arrange for sample delivery
7/24/81 V-14 RCRA INSPECTION MANUAL
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b. Record all sample information in a field notebook.
c. Fill out the sample analysis request sheet.
d. Fill out Receipt-of Sample form.
10. Deliver or ship the samples to the laboratory for analysis.
In some cases, it may be appropriate to conduct a preliminary survey of
the facility prior to sampling. This would consist of a brief site visit
and survey during which safety requirements of the site would be ascertained
and a sampling plan established by the inspector.
In developing a sampling plan, the inspector should include the points
discussed below.
1. Safe Sampling Procedures
The sampling plan should delineate the safety procedures for sample
collection such as respiratory protection required while sampling concen-
trated sources, procedures for entering buildings or enclosed structures,
length of time personnel are to remain in protective clothing while sam-
pling, and identification of the person handling the field samples. Proper
procedures must be used when opening drums, tanks, or other vessels, and all
personnel must be notified when closed containers will be opened.
The sampling plan also should 11st telephone numbers and addresses of
and directions to the nearest nedlcal facility, ambulance service, fire
department, police department, and EPA Office contact. Much of this Infor-
mation 1s available in the contingency plan required of the facility under
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9938.2
Section 255 Part 0 of the RCRA regulations. The fire department should be
alerted to possible incidents during a very hazardous inspection.
2. Sampling Points
A representative sample is crucial to enforcement proceedings and is
dependent on proper selection of sampling points. Hazardous wastes are
usually multi-phase mixtures and are stored In receptacles of different
sizes and shapes. No single series of sampling points can be specified for
all types of receptacles. Table 1 lists most types of receptacles used for
hazardous waste and the corresponding recommended sampling points.
3. Volume of Samples
Sufficient volume of a sample, representative of the main body of the
waste, must be collected. This sample must be adequate in size for all
needs, Including laboratory analysis, splitting with other organizations
involved, etc. In collecting liquid waste samples in drums, vacuum trucks,
or similar containers, 1000 ml of a sample ,is usually sufficient. Hazardous
wastes usually contain high concentrations of the hazardous components, so
only a small aliquot of the sample is used for analysis. In all cases, a
laboratory should be consulted for guidance prior to sampling.
4. Sampling Equipment
Receptacles (i.e., drums, tanks, etc.), should only be sampled when
necessary to tieet enforcement or cleanup requirements. Opening of drums or
other sealed receptacles nay be hazardous to sampling personnel unless
proper safety procedures are fallowed. Cases can be released, or pressur-
ized liquids can be expelled. Drums should not be moved or opened unless 1t
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TABLE 1
SAMPLING POINTS FOR MOST WASTE RECEPTACLES
Receptacles
Drum, bung on one end
Drum, bung on side
Barrel, fiberdrum,
buckets, sacks, bags
Sampling Point
Vacuum truck and similar
containers
Pond, pit, lagoons
Waste pile
Storage Tank
Soil
Withdraw sample through the bung opening.
Sample drums only if they are laying on
side with bung up. Withdraw sample
through the bung opening.
Withdraw samples through the top of bar-
rels, fiberdrums, buckets, and similar
receptacles. Withdraw samples through
fill openings of bags and sacks. With-
draw samples through the center of the
receptacles and to different pionts
diagonally opposite the point of entry.
Withdraw sample through open hatch.
pie all other hatches.
Sam-
Divide surface area into an imaginary
grid. Take three samples, if possible;
on sample near the surface, one sample at
mid-depth or at center, and one sample at
the bottom. Repeat the sampling at each
grid section over the entire pond or
site.
Withdraw samples through at least three
different points near the top of pile to
points diagonally opposite the point of
entry.
Sample from the top through the sampling
hole.
Divide the surface area Into an imaginary
grid. Sample each grid section.
* The number of grid sections 1s determined by the desired number of
samples to be collected which, when combined, should give a
representative sample of the wastes.
Source: de Vera et al, "Sampling Procedures for Hazardous Wastestreams;"
modified slightly by Fred C. Hart Associates, Inc.
7/24/81
V-17
RCRA INSPECTION MANUAL
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S938.2
can be ascertained beyond a reasonable doubt that the drum being moved is
structurally sound. Drums standing on end, with bung up, should be opened
by pneumatic impact wrench, operated from a remote site. Drums on sides may
be opened similarly if it is possible to safely rotate the drum so that the
bung is high. If the bung can be removed, sampling of contained liquids may
be safely accomplished by a glass tube, which is then broken and discarded
within the barrel. Barrels that have badly rusted bungs, or which cannot be
sampled as above, may be safely sampled with a hydraulic penetrating device
operated remotely. The device is then abandoned in place and disabled to
prevent further withdrawal of liquids.
As a general rule, sampling equipment used on hazardous waste sites
should be disposable. Dippers, scoops, and similar devices for solids
samples should be buried on-site or placed in plastic bags for later dis-
posal. Liquid samples from barrels or tanks should be withdrawn in Inert
tubing such as glass, and the tubing should then be broken and abandoned
within the barrel or tank. If incineration or recycling of barrel contents
is contemplated, disposal of the tubing may be in other suitable receptacles
or by burial on the site.
In cases where sampling equipment 1s reusable, decontamination of the
equipment is necessary to evoid cross-contamination. Sampling equipment
oust be thoroughly cleaned with either soap and water or solvent.
In general, metal sample containers should not be used on hazardous
waste site Investigations, but 1f used oust be grounded, preferably to the
drum or tank being sampled, while sample transfer is accomplished.
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Ambient air sampling on hazardous waste sites must be accomplished with
spark-free equipment if explosive vapors are present (most hi-vol samplers
are spark sources).
Following is a list of sampling equipment. The list is subdivided into
five sections: sampling equipment, testing equipment, shipping and packing
equipment, documentation equipment, and other equipment. The sections
following will discuss the application of the listed equipment.
Sampling Equipment
Sampling plan;
Sample containers (plastic and glass), caps, liners;
Shovels;
Soil samplers (auger, scoop, steel spoon, etc.);
Stainless steel buckets;
Remote barrel opener equipment, non-sparking bung
wrench;
Thermometer;
Colorimetric gas detector tubes;
Tenax columns and power packs;
Ambient air monitor;
Surveyor's ribbon;
Glass pipets and glass tubing;
Wooden paddles (tongue depressors); and
Monitoring well sampling equipment (see Section E.6,
Groundwater and Leachate Monitoring).
Testing Equipment
Well sounder;
Radiation detector (beta, gamma) (see Section II.0.);
Explosimeter (see Section II.D);
pH paper;
pH meter, spare probes; and
Flash point cup.
Shipping and Packing Equipment
DOT spec 12B outer cartons;
DOT spec quart metal cans;
Vermiculite or equivalent packing material;
4 nil plastic bags;
Shipping papers;
Labels;
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Custody locks;
Tape;
Metal picnic coolers;
DOT spec 3A1800 or 3AA1800 metal cylinders (for Class A
poisons); and
String or flexible wire.
Documentation Equipment
Water proof felt tip pen;
Sample tags (see Figure 4);
Chain-of-custody transfer forms (see Figure 5);
Log books;
Field document records (selected from facility compli-
ance file);
Inspection forms (checklists, sample receipts, etc.);
and
Evidence tape.
Other Equipment
Duct tape;
Electrical tape;
Fiber tape;
Nylon rope; and
Plastic covers/ground cloth.
5. Sampling Procedures
Sampling procedures will vary depending on the medium sampled (liquid,
solid, or gas) and the type of structure the waste 1s contained in. Refer-
ences for sampling procedures include the "NPOES Compliance Sampling
Manual," U.S. EPA, Office of Water Enforcement (October, 1979) and "Sampling
Procedures for Hazardous Wastestreams," de Vera el. al., California
Department of Health Services.
The following procedures are recommended for campling the hazardous
wastes In various media and types of receptacles.
7/24/81 V-20 RCRA INSPECTION MANUAL
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a. Sampling a Drum. In a number of situations, drums should not be
sampled. Drums containing liquid wastes may be under pressure. A bulging
drum usually indicates that it is under high pressure and should not be
sampled until the pressure can be safely relieved. A heavily corroded or
rusted drum can readily rupture and spill Us contents when disturbed. It
too should not be sampled. Opening the bung of a drum can produce a spark
that might detonate an explosive gas mixture in the drum. This situation is
difficult to predict and must be taken into consideration every time a drum
is opened.
If a drum must be sampled, choose a drum and position yourself so as to
minimize the potential for danger. The importance of using full protective
equipment when, sampling a drum cannot be overemphasized.
After observing all recommended safety precautions, the following pro-
cedures should be observed:
Choose a drum whose bung is up. (Drums with the bung on the
ends would be positioned upright. Drums with bungs on the
side would be lying on the side with the bung up.)
Slowly loosen the bung with a hydraulic penetrating device
operated remotely allowing any gas pressure to release. If
such a device is not available, use a non-sparking bung
wrench.
Remove the bung and collect a sample through the bung hole
with a disposable glass tube which should be broken off
afterwards and left in the drums.
When there 1s more than one drum of wastes to be sampled at a
site, segregate the drums according to waste types and use a
table of random numbers (consult a statistics reference) to
determine which drums to sample.
b. Sampling a Vacuum Truck. Sampling a vacuum truck requires opening
a drain plug or collecting a sample from the tank hatch using glass tubing,
7/24/81 V-21 RCRA INSPECTION MANUAL
-------
9938.2
suction hose, or dipper. In some trucks obtaining a sample requires climb-
ing access rungs to thg tank hatch. These situations present accessibility
problems to the sample collector who, in addition, -.Dually has to wear full
protective sampling gear. Preferably, two persons should perform the sam-
pling: one person to do the actual sampling; the other to hand the sampling
device to the sampler, to stand ready with the sample container, and to aid
in case of any problems. The sample collector positions himself to collect
samples only after the truck driver has opened the tank hatch. The tank is
usually under pressure or vacuum. The driver should open the hatch slowly
to release pressure or to break the vacuum.
After observing all recommended safety precautions the following proce-
dures are followed:
Let the truck driver open the tank hatch.
Using protective sampling gear, assume a stable stance on the
tank catwalk or access rung to the hatch.
Collect a sample through the hatch opening with a glass tube
which should be removed and disposed of properly.
If the tank truck is not horizontal, take one additional
sample each from the rear and front clean-out hatches and
combine all three samples in the same sample container.
When necessary, carefully take a sediment sample from the
tank through the drain spigot.
c. Sampling a Barrel. Fiberdrum. Can. Bags, or Sacks Containing Powder
or Granular Waste. The proper protective respirator. In addition to other
protective gear, must be worn when sampling dry powdered or granular wastes
in these containers. These wastes tend to generate airborne particles when
the containers are disturbed. The containers Bust be opened slowly. The
7/24/81 V-22 RCRA INSPECTION MANUAL
-------
barrels, fiberdrums, and cans must be positioned upright. If possible,
sample sacks or bags in the position you find them. Standing them upright
might rupture them.
After observing all recommended safety precautions, the following pro-
cedures are used:
Collect a composite sample from the container with a grain
sampler, sampler trier, stainless steel spoon, or stainless
steel shovel.
When there is more than one container of wastes on a site,
segregate the containers by waste type and sample according
to a table of random numbers.
d. Sampling a Pond. Storage or evaporation ponds for hazardous waste
vary greatly in size from a few meters in diameter to more than one hundred
meters. It is difficult to collect representative samples from the large
ponds without incurring astronomical expense and assuming excessive risks.
Any samples desired beyond 3.5 meters frolrrthe bank nay require the use of a
boat, which is very risky, or the use of a crane or a helicopter, which is
very expensive. The information sought must be weighed against the risk and
expense involved in collecting the samples. A pond sampler can be used to
collect samples as far as 3.5 meters from the bank. (See "Sampling Proce-
dures for Hazardous Wastestreams," by deVera et al.)
After observing all recommended safety procedures, the following pro-
cedures are used:
Collect a composite sample with a pond sampler from different
distances and different depths.
Combine samples Into one composite sample.
7/24/81 V-23 RCRA INSPECTION MANUAL
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9933.2
e. Sampling Soil. The techniques of soil sampling are numerous. The
procedures outlined below are consistent with the hazardous waste management
objectives of collecting soil samples generally to determine the amount of
hazardous material deposited on a particular area of land or to determine
the leaching rate of the material and/or to determine the residue level on
the soil. There are elaborate statistically designed patterns for sampling
soils. To use one of these patterns, a good statistics book may have to be
consulted. In the following procedures, soil samples are taken in a grid
pattern over the entire site to ensure a uniform coverage of the site.
After observing all recommended safety precautions, the following pro-
cedures are used:
Divide the area into an imaginary grid.
Sample each section of the grid and combine the samples into
one composite sample. (Do not combine when sampling for
highly contaminated areas.)
To sample*up to 8 cm deep, collect samples with a scoop or
spoon.
To sample beyond 8 cm deep, collect samples with a soil auger
or Vei hmeyer soi1 samp1er.
f. Sampling a Waste Pile. A waste pile can range from a small heap
to a large aggregate of wastes. The wastes are predominantly solid and can
be mixtures of powders, granules, and large chunks. A number of core sam-
ples, depending on the size of the waste pile, have to be taken at different
angles and composited in order to obtain a sample which on analysis will
give average values for the hazardous components In the waste pile.
7/24/81 V-24 RCRA INSPECTION MANUAL
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After observing all recommended safety precautions, the following pro-
cedures are used:
Determine the sampling points.
Collect a composite sample with a core sampler.
g. Sampling a Storage Tank. Sampling a storage tank requires great
manual dexterity. Usually it requires climbing to the top of the tank
through a narrow vertical or-spiral .stairway while wearing protective equip-
ment and carrying sampling paraphernalia. At least two persons must always
perform the sampling: one to collect the actual samples; the other to stand
back, usually at the head of the stairway, and observe, ready to assist or
call for help in case of problems. The sample collectors must be accompan-
ied by a representative of the company who must open the sampling hcle,
which is usually located on the tank roof.
After observing all recommended safety precautions, the following pro-
cedures are used:
Collect one sample each from the upper, middle, and lower
sections of the tank contents with a weighted bottle sampler.
Combine the samples In one container and submit it as a
composite sample.
h. Sampling Air. Procedures for obtaining air samples will depend
partially on the type of sampling equipment used (e.g. Orager tubes, plastic
bags, Tenax columns, etc.) Specific directions for each type of equipment
should be adhered to. For general air sampling methodology and analysis
Information, the following references are available:
7/24/81 V-25 RCRA INSPECTION MANUAL
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9938.2
"EPA/3ERL-RTP Interim Procedures for Level 2 Sampling and Analysis
of Organic Materials," U.S. EPA Office of Research and Develop-
IT ant, EPA-600/7-78-016, February, 1978.
"IERL-RTP Procedures Manual: Level 1 Environmental Assessment
(Second Edition)," U.S. EPA Office of Research and Development,
EPA-600/7-78-201, October 1978.
"Methods of Air Sampling and Analysis," ed. Morris Katz, Ph.D.,
American Public Health Association, Washington, D.C. 1977.
"Quantitative Analysis of Gaseous Pollutants," Walter E. Rucn,
Ph.D. Ann Arbor-Humphrey Science Publishers, Ann Arbor, Michigan,
1970.
"The Analysis of Air Pollutants," W. Leithe, Ann Arbor Science
Publishers, Ann Arbor, Michigan, 1971.
6. Groundwater and leachate Monitoring
Monitoring at the site should meet the objectives of establishing the
presence or absence of contaminants and of determining the need for further
monitoring. If contaminants are found, monitoring to determine the extent
of damage should be done at a later date. Monitoring Mils should be In-
stalled in compliance with regulatory requirements.
Following is a list of necessary equipment for sampling monitoring
MelIs:
sampling pump (submersible or surface);
pump accessories (connector tubing);
well bailer with line (SO1 nylon cord);
jetting with nitrogen;
electric water level Indicator (volt-ohm meter);
steel tapes (with chalk and rags); and
pipe wrench.
7/24/81 V-26 RCRA INSPECTION MANUAL
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When sampling a monitoring well, the following procedure should be
followed:
Check the well for above ground damage.
Remove the well cap (a wrench nay be needed).
Measure and record the depth to water.
Measure the total depth of the well.
Determine the amount of water in the well (depth of water x
surface area).
If possible, dewater the well by removing a minimum of three
volumes and allow the well to recharge.
Collect the sample. If using a pump,
a. Make sure the pump 1s resting on a stable surface.
b. Lower the tubing below the water level. Oo not lower to
the well bottom.
c. Restart the pump and collect the water in the proper
bottles.
d. Upon completion of sampling, remove the tubing from the
well allowing the pump to "pump itself dry." However,
do not pump longer than necessary with both ends of
tubing out of the water.
If using a bailer,
a. Lower the bailer slowly down the well until it comes in
contact with the water. Oo not stir up the bottom
sediment by dropping the bailer rapidly.
b. Slowly submerge the bailer, letting it fill up and
remove the bailer filled with water from the well.
When sampling a hydrant or pump well (tap), follow the same procedure used
with a monitoring well with the following exceptions. Let the water run for
a minimum of 5 minutes to rid the well of stagnant water. The depth to the
water and the height of the easing cannot be recorded.
7/24/81 V-27 RCRA INSPECTION MANUAL
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7. ContaineHzation ang Handling oo**a *>
°938•2
The type of container chosen will depend upon the composition of the
waste sampled. In all cases, however, glass bottles, jars, or vials should
be used (brown glass for photosensitive wastes). Closures should be bake-
lite caps with teflon liners. All sample containers must be cleaned and
free of residual waste material on their exteriors prior to shipment.
Sample containers should be filled to capacity.
After a sample is transferred into the proper sample container, the
container must be tightly capped as quickly as possible to prevent the loss
of volatile components and to exclude possible oxidation from the air.
The use of a preservative or additive is not recommended. However, if
only one or two components of a waste are of interest, and these components
are known to rapidly degrade or deteriorate chemically or biochemically, the
sample may be refrigerated at 4°C to 6°C or treated with preservatives
according to Table 2.
6. Chain-of-Custody
After collection and Identification, the samples are maintained under
Chain-of-Custody procedures. If the sample collected 1s to be split with
the owner or operator of the site or with other regulatory agencies, It
should be aliquoted Into similar sample containers. Sample tags (Figure 6)
with Identical information are attached to each of the samples and are
7/24/81 V-26 RCRA INSPECTION MANUAL
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TABLE 2
Measurement
Acidity
Alkalinity
Ammonia
Arsenic
Chlorine
Cnroaiua (VI)
Cyanides
Fluoride
Metals:
1) dissolved
2) suspended
3) Total
Mercury
1) dissolved
2) Total
pH
Phenolic*
Residue, volatile
Seltnlin
Specific conductance
Sulfldt
Sulflde
Zinc
METHODS OF PRESERVATION
Preservation
Cool, 4°C
Cool, 4*C
Add 1 tt1 cone. K2$04/l
Add 6 Bl cone. HN03/1
Cool, 4«C
Add 6 B! cone. H2S04/1
Cool, 4°C; add 2.5 Bl of
SOS NaOH/1
Cool, 4*C
Filter on site, add 5 •!
cone. KN03/1
Filter on site
Add 5 B! cone. HNQ3/1
Filter, add 5 B! cone. HNOj/1
Add 5 Bl cone. HN03/1 .
Oat. on slta; cool, 4*C
Add K-PO, to pH 4 and
1 g. CuSO./l
Refrigerate to 4*C
Cool, 4*C
Add 5 Bl cone. HN03/1
Cool,- 4°C
Add 2 Bl of 2N Zn(AC)2/1
Cool, 4"C
Add 4 B! cone. HCU1
Storage
Tine
7- days
6 Bonths
6 months
6 Bonths
38 days
3S days
6 hours
24 hours
7 days
€ Bonths
24 hours
24 hours
24 hours
7/24/81
V-29
RCRA INSPECTION MANUAL
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FIGURE 6
SAMPLE IDENTIFICATION
?rc;«s: Cce:
Jution LKitten
2,
6 r
*tj •
£
1
?
1
*r
e
5"
e
£
Lagenlclty
n
iticldes
e
n
e
1C
3
«•
n
*
?
o
e
1
cr
1
s
a
n
M
CORID.
Grab
*""'" li"MU"t.>;
9
=.
ff>
o>
M
n
^
Jr
M
Mercury !
Htenollcs 1
9
0
p
p
e
!T
ST
tA e
o o
— >o
?
IE
I5
M
M
ANALYSES 1
Preservative:
Yes D Ho D
e
(obverse)
UNITED STATES EKYIRDNICKTAL PROTECTION Afi-NCY
(Appropriate Address)
EPA
(reverse)
7/24/81
V-30
RCRA INSPECTION MANUAL
-------
marked as "Company Split" or "Split." If air samples are to be given to the
Company, duplicate samples must be collected. The requesting official is to
be notified that the company must supply the containers for the company
splits.
Each person involved with the sample must know Chain-of-Custody pro-
cedures. The procedures should be included in the Project Plan or be pub-
lished and available to all personnel. Due to the evidentiary nature of
sample-collecting investigations, the possession of samples must be trace-
able from the time the samples are collected until they are introduced as
evidence in legal proceedings. To maintain and document sample possession,
Chain-of-Custody procedures are followed.
Sample Custody
A sample is under custody if:
a. it is in the sampler's actual possession; or
b. it is in the sampler's view, after being in his/her
physical posession; or
c. it was in the sampler's physical possession and then
he/she locked it up to prevent tampering; or
d. it is in a designated and identified secure area.
Field Custody Considerations
a. As few people as possible should handle the samples.
b. The field sampler is personally responsible for the care
and custody of the samples until they are transferred or
properly dispatched.
Transfer of Custody and Shipment
a. Samples must be accompanied by a Chain-of-Custody Record
(see Figure 7). When transferring the possession of
samples, the Individuals relinquishing and receiving
will sign, date, and note the time on the Record. This
7/24/81 V-31 RCRA INSPECTION MANUAL
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^ ENVIRONMENTAL PROTECTION AGENCY
73
FIGURE 7
CHAIN OF CUSTODY RECORD
(Appropriate Address)
00
P»o| No.
Project Name
SAMPLERS'
ft A. MO.
IMM
in ME
NO
or
COM-
STATION tOCATION
REMARKS
Relinquished by: rs«Mii»tf
Relinquished by:
Rannqulshod by:
Dala/Tlnw
DalerTlina
Data/Time
Received hy:
nellnqulshed by:
necalved by: (Sipn»ri»«i
Relinquished by:
Raeelved for Lnbor*lo*y by:
Uala/Tlme
Dltlrlhullon: Origin*! Accomp«nl»i Shlpmanl; Copy 10 Coordinator FtaM
Uole/rimo
Received by
Dale/Time
ncmarkt
-------
FIGURE 7 Continued
Chain of Custody Record
Instructions
The Chain of Custody Record will be filled out by providing the infor-
mation requested. These information requirements are described below.
1. Project Number. The facility's EPA Identification number.
2. Project Name. The name and address of the facility.
3. Sampler(s). The EPA inspector(s) names.
4 Station Number. The number of the station from which a sample
was taken.
5. Date. The date a sample was taken.
6. Time. The time a sample was taken.
7. Composite. Indicate if the sample was a composite sample.
8. Grab. Indicate if the sample was a grab sample.
9. Station Location. The direction (north, south, etc.) and prox-
imity of the sample station to a benchmark.
10. Number of Containers. Number of sample containers taken from
station and by each method of sampling.
11. Analysis Desired. Type ?f analysis desired to be performed on
the waste, i.e. BOD, metals, insecticide testing.
12. Remarks. Additional information about the samples such as the
type of media sampled or type of container sampled.
13. Relinquished by: (Signature). The signature of the sampler(s).
14. Date/Time. The date and time the sample was relinquished.
15. Received by: (Signature). Whoever receives the sample, most
likely a shipper, oust sign for it.
16. Received for Laboratory by: (Signature). The signature of a
person at the lab who officially accepts the samples.
17. Date/Time. The date and time the sample 1s received by the lab-
oratory.
18.- Remarks. Final remarks about the samples after acceptance by the
laboratory.
Note: Chain of Custody must continue for handling of the sample at the lab-
oratory.
7/24/81 V-33 RCRA INSPECTION MANUAL
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Record documents transfer of custody of samples from the
sampler to another person, to a mobile laboratory, or to
the permanent laboratory. The form should be filled out
as described in the attached instructions In Figure 5.
b. Whenever samples are split with a facility or government
agency, a separate Chain-of-Custody Record is prepared
for those samples and marked to indicate with whom the
samples are being split.
c. All packages will be accompanied by the Chain-of-Custody
Record showing identification of the contents. The
original Record will accompany the shipment, and a copy
will be retained by the inspector.
d. If sent by a*common carrier, a Bill of Lading should be
used. Receipts of Bill of Lading will be retained as
part of the permanent documentation.
F. PACKAGING. LABELING. AND SHIPPING
Each sample must be labeled and sealed properly immediately after
collection. Procedures must be In compliance with the DOT regulations that
are specific to the type of wastes sampled (see Appendix III on Agency
policy for compliance with the Hazardous Materials Transportation Act and
Appendix IV on DOT regulations for Hazardous Materials Transport). For
additional information, the inspector should consult with the Regional
Safety Officer prior to a site visit.
If the contents of a hazardous waste container are known, the material
can be labeled and packaged according to hazardous waste classes in 49 CFR
172.101, Hazardous Materials Table, which contains: (a) whether the mater-
ial is subject to vessel or aircraft transport restrictions; (b) hazardous
materials descriptions and proper shipping names; (c) hazard class; (d)
labels required; (e) packaging; (f) maximum net quantity in a package
depending on type of transport; and (g) requirements for water shipments.
7/24/81 V-34 RCRA INSPECTION MANUAL
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Problems occur with how to classify, package and label a package for
shipment when the exact composition the material is not known. New
Department of Transportation (DOT) reg> stions (49 CFR 173.1300, effective
November 20, 1980) specify the use of new designations: "Hazardous Waste,
Liquid, n.o.s." or "Hazardous Waste, solid, n.o.s." and a new hazard class,
ORM-E. However, the ORM-E class applies only when the material 1s not
included in any other DOT hazard class but is subject to DOT requirements
because it may pose an unreasonable risk to health and safety or property
when transported in commerce. If, based on the information available, the
shipper believes that a hazardous waste site sample may contain a DOT regu-
lated material, then the sample must be packaged and labeled according to
the requirements set forth in the DOT hazardous materials table (49 CFR
172.101).
For all samples, a Chain-of-Custody Record Form (Figure 7) should be
properly executed and included in the exterior container. The purpose of
this document is to trace sample possession from the time of collection.
The inspector also should be prepared to fill out a "Receipt for Samples" 1f
the owner/operator of the facility should request one. A sample receipt
form 1s shown in Figure 8.
Samples to be packaged, marked end shipped are comprised of 1) envlron-
Mntal samples and 2) hazardous samples. Hazardous samples are categorized
Into a) samples excluding closed container samples and b) samples from
closed containers. The procedures for Identifying and packaging each type
of sample are differentiated 1n the DOT regulations and separately discussed
below.
7/24781 V-35 RCRA INSPECTION MANUAL
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FOR
38.
FOR SAMPLES FOP,M
A* PIOTICTIOM iClNCT
KECSIPT FOR (AMPLE!
Html
MO«IU
Cur. •«» MM fa*
desc-fstion, ard-ethe- positive
to the Resource Conservation ai.d Recovery Act, Section 3007(a).
IM
The unaerslgneo acknowledges that the sampled] and/or docunent(s) described
above were obtained at thr 1nc»t<»» »nd nnrt«.
M6 •MVItCI
i iR'V^fii^*
I'll
I !«••»
I' I •• «» •»
•«•! •'
T
Note: This fora 1s undergoing Agency review. A final form will be distributed
at a later date, accompanied by a separate trann
-------
1. Environmental Samples. "Environmental samples" are those obtaine.d
offsite, which are mildly contaminated (e.g., surface runoff) and are suit-
able for analysis in environmental laboratories. Such samples are not
considered DOT hazardous unless there is evidence to the contrary, and they
may be packaged and shipped by conventional methods, taking care, of course,
that proper Chain-of-Custody and sample identification procedures are fol-
lowed.
2. Hazardous Waste Samples. For those samples collected from haz-
ardous waste facilities which cannot be considered "environmental" samples,
the following provisions apply:
Unanalyzed hazardous waste (HW) samples may not be fixed with
any preservative or preserved with ice or dry ice.
If a material identified in the Department of Transportation
(DOT) Hazardous Material Table (49 CFR 172.101) is known to
be contained in a KW sample, that sample should be trans-
ported as prescribed in the table. Specific exemptions to
the hazardous waste classification may also apply (e.g., use
of Labelmaster, Inc. package #38, or Dow Chemical Co. Imbiber
Pack for shipment of Poison B, n.o.s. by United Parcel
Service or letters of understanding granted by an agency by
DOT).
Unanalyzed HW samples may be transported by rented or common
carrier truck, bus, railroad, and "cargo only" aircraft; but
they may not be transported by passenger-carrying non-govern-
ment aircraft.
If samples are transported by any type of government-owned
vehicle, including aircraft, DOT regulations are not applic-
able. However, EPA RCRA regulations now apply to federal,
state and local governments. Therefore, EPA personnel will
use the packaging procedures described below tnd a bill of
lading certification fora should be prepared in legible
handwritten or typed form. The bill of lading must be
clearly distinguishable as a hazardous material shipping
paper. It oust be within reach of the driver while re-
strained by a seat belt and be readily visible to a person
entering the driver's compartment.
7/24/81 V-37 RCRA INSPECTION MANUAL
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The following preliminary procedures should be followed before haz-
ardous waste samples are shipped:
Conduct a radiation measurement to eliminate the possibility
of a sample being radioactive. If the sample is radioactive
it should not be handled and the Regional or State Office
should be contacted.
Place a sufficient quantity of sample in glass containers to
determine whether sample material will react with or substan-
tially reduce the effectiveness of the container. (This
should be done at time of sampling).
.Specific packaging, marking, labeling, and shipping requirements for (a)
samples excluding those from closed containers and (b) those from closed
containers are delineated below:
a. Hazardous Waste Samples, Excluding Closed Container Samples.
Samples taken front onsite are considered to be heavily contaminated and as
hazardous as a flammable liquid (or flammable solid) and should be packaged
accordingly. This is because the prioritized DOT classification above
establishes only radioactive materials, poisons A, and gases as more haz-
ardous than flammables. The presence of radioactive materials is eliminated
by the use of geiger counters for personnel safety when entering a site;
Poisons A are not present (see discussion below on third sample level) and
gases are normally not sampled or shipped. Moreover, flashpoint testing of
samples, at a hazardous waste site, 1s Impractical and extremely hazardous.
Packaging consists of the sample bottle sealed 1n e plastic bag, In
turn sealed Inside a metal can, packed 1n a locked metal box with absorbent,
non-combustible filler material 1n and surrounding the can. More detailed
discussion of this packaging and labeling procedure 1s provided below:
7/24/81 V-38 RCRA INSPECTION MANUAL
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1. Collect sample in a 16-ounce or smaller glass or polyethylene
container with nonmetallic, teflon-lined screw cap. Allow
sufficient ullage (approximately 10% by volume) so container
is not liquid full at 130°F. If collecting a solid material,
the container plus contents shall not exceed 1 pound net
weight.
2. Attach properly completed sample identification tag to sample
container.
3. Seal sample container and place in 2-mil-thick (or thicker)
polyethylene bag, one sample per bag. (Tags should be posi-
tioned to enable them to be read through bag.)
4. Place sealed bag inside a metal can with incombustible,
absorbent cushioning material (e.g., vermiculite) to prevent
breakage, one bag per can. Pressure-close the can and use
clips, tape or other positive means to hold the lid securely,
tightly and effectively.
5. Mark and label the container as indicated in No. 8 below.
6. Place one or more metal cans, surrounded with incombustible
packaging material for stability during transport, into a
strong outside container, such as a picnic cooler or a fiber-
board box.
7. Hark and label the outside container and complete shipping
papers as described in No. 8 below.
8. Marking and Labeling: Use abbreviations only where speci-
fied. Place the following information on a metal can, either
hand printed or in label form: Laboratory name and address
and "Flammable, liquid, n.o.s. UN1993, (if not liquid, write
"Flammable Solid, n.o.s." UN1325). Place the following
labels on the outside of the can next to one another and near
the Flammable liquid marking:
"Cargo Aircraft Only"; "Flammable Liquid, n.o.s."
Note: If the cans are placed in an exterior container, both
that container and Inside cans must have the same markings
and labels as above. "Laboratory Samples", "Limited Quanti-
ty," and "THIS SIDE UP" or "THIS END UP" should also be
marked on the top of the outside container.
9. Shipping Papers: Use abbreviations only where specified
below.
Complete the bill of lading and sign the certification state-
ment with the following Information in the order listed. One
form may be used for more than one exterior container, and
"Flammable Liquid" or "Flammable Solid" as the hazard class.
"Flammable Liquid, n.o.s. UN1993" or "Flammable Solid, n.o.s.
UN 1325" as appropriate; "Cargo Aircraft Only"; "Net
7/24/81 V-39 RCRA INSPECTION MANUAL
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9S38-2
Weight " or "Net Volume " (of hazardos contents), by
item, if more than one metal can is inside an exterior con-
tainer.
A Chain-of-Custody Record form should also be properly exe-
cuted, and included in,ihe exterior container.
10. Unless samples are driven to the laboratory, an agency em-
ployee will accompany shipping container(s) to the transport
carrier and, if required, open outside container(s) for
freight inspection.
When transporting samples to a laboratory for analysis, if a reasonable
doubt exists as to sample* class and labeling requirements, DOT (49 CFR
173.2) indicates that the material should be classed according to the fol-
lowing order of hazards:
1. Radioactive material
2. Poison A
3. Flammable gas
4. Non-flammable gas
5. Flammable liquid
6. Oxidizer
7. Flammable solid
8. Corrosive material (liquid)
9. Poison B
10. Corrosive material (solid)
11. Irritating materials
12. Combustible liquid (in containers having
capacities exceeding 110 gallons)
13. ORH-B
14. ORM-A
15. Combustible liquid (in containers having capacities of 110 gallons
or less.)
16. ORM-E (Hazardous Waste)
b. Hazardous Waste Samples Taken From Closed Containers. The third
level of hazard, for shipping purposes, Is for materials taken from closed
containers where limited or no Information is available on the contents.
Samples are shipped as a DOT Poison A material, and gas cylinders are used
for packaging as outlined In Appendix B. Poison A (49 CFR 173.326) Is a
class reserved by DOT for materials which are extremely dangerous to life.
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DOT defines Poison A as extremely dangerous poisonous gases or liquids of
such nature that a very small amount of the gas, or vapor of the liquid,
mixed with air is dangerous to life. This class includes the following:
Bromaceton
Cyanogen
Cyanogen Chloride containing less than 0.9% of water
Diphosgene
Ethyldichlorarsine
Hydrocyanic acid over 5% strength
Methyldichlorarsine
Nitrogen peroxide (tetroxide)
Phosgene (diphosgene)
Nitrogen tetroxide-nitric oxide mixtures containing
up to 33.2% weight nitric oxide
Packaging and labeling procedures are delineated below:
1. All samples from closed drums must be packaged as "Poison A"
(49 CFR 173.328).
2. These samples classed as "Poison A" may not be transported by
non-government aircraft.
3. Collect sample in a polyethylene or glass container which is
of an outer diameter narrower than the valve hole on a DOT
Spec. 3A1800 or 3AA1800 metal cylinder. Fill sample con-
tainer allowing sufficient ullage (approximately 10% by
volume) so it will not be liquid-full at 130°F.
4. Attach properly completed Sample Identification Tag to sample
container.
5. With a string or flexible wire attached to the neck of the
sample container, lower it into a metal cylinder which has
been partially filled with Incombustible, absorbent, loose-
packaging material (vermiculite). Allow sufficient cushion-
ing material between the bottom and sides of the container
and the metal cylinder to prevent breakage. After the cylin-
der 1s filled with cushioning material, drop the ends of the
string or wire into the cylinder valve hole. Only one sample
container nay be placed in a metal cylinder. Replace valve
and valve protector or metal cylinder.
6. Marking and labeling: Use abbreviations only where speci-
fied. Place the following Information on the side of the
cylinder, or on a tag wired to the cylinder valve protector,
either hand-printed or in label form:
"Poisonous, liquid or gas, n.o.s. NA 98035," laboratory name and
address, and "Poison A."
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Note: If the metal cylinders are placed In an outside con-
tainer, both the container and cylinders inside must have the
same markings and labels as above. In addition, "Laboratory
Sample," "Inside Packages Comply With Prescribed Specifica-
tions" and "THIS SIDE UP" or "THIS END UP" should be marked
on the top of the outside container.
7. Shipping Papers: Complete the bill of lading and sign the
certification statement with the following information in the
order lised. One form may be used for more than one exterior
container; use abbreviations only as specified.
"Poisonous Liquid or gas, n.o.s. NA9035;" "Limited Quantity"
or "Ltd. Qty."; "Laboratory Samples"; "Net Weight " or
"Net Volume " (of hazardous contents), by cylinder, -if
more than one cylinder is inside an exterior container, and
"Poison A" for hazard class.
A Chain-of-Custody Record should also be properly executed
and included in the container.
8. Unless samples are driven to the laboratory, an EPA employee
will accompany shipping container(s) to the transport carrier
and, if required, open outside container(s) for freight
inspection.
G. QUALITY ASSURANCE
The objectives of quality assurance (QA) are to produce data that meet
user requirements in terms of completeness, precision, accuracy, representa-
tiveness, and comparability. Control checks should be performed by the
inspector during the actual sample collection. These checks are used to
determine the performance of the sample collection system. In general, the
most common errors produced in monitoring are usually caused by Improper
sampling, poor preservation, or lack of adequate mixing during compositing
and testing. The following checks will help the Inspector and QA Coordina-
tor to determine when the sample collection system 1s out-of-control.
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1. Duplicate Samples. At selected stations on & random time frame,
collect duplicate samples using the field equipment installed at the site.
If automatic sampling equipment is not installed at the site, collect dupli-
cate grab samples. This will provide a proficiency check for precision.
2. Split Samples. Aliquots of the collected sample may be given to
the permittee, if requested, as a check on the permittee's laboratory pro-
cedures. For air samples taken, a dual system roust be run. Differences
between Agency and permittee's results can then be evaluated and the cause
of the difference usually identified. Having the permittee analyze known
performance samples will aid in identifying discrepancies in the permittee's
analytical techniques and procedures.
3. Spiked Samples. Known amounts of a particular constituent should
be added to an actual sample or blanks of deionized water should be added at
concentrations where the accuracy of the method is satisfactory. The amount
added should be coordinated with the laboratory. This method will provide a
proficiency check for accuracy of the field sampling procedures. However,
if a GC mass spectrometer is available, this procedure is not necessary.
4. Sample Preservative Blanks. Acid and other chemical preservatives
can become contaminated after a period of use in the field. The sampler
should add the same quantity of preservative to a sample of distilled water
as normally would be added to the wastewater sample. This preservative
blank is sent to the laboratory for analysis, and the blank is subtracted
from the sample value. Liquid chemical preservatives should be changed
every two weeks or sooner if contamination occurs.
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9938.2
5. Precision. Accuracy, and Control Charts. A minimum of seven sets
(»ach of comparative data for duplicates, spikes, split samples, and blanks
should be collected to define acceptable estimates of precision and accuracy
criteria for data validation. See EPA's "Handbook for Analytical Quality
Control in Water and Wastewater," or W.J. Youden's "Statistical Techniques
for Collaborative Tests," for discussion of precision, accuracy, and quality
control charts, and their calculations.
Quality assurance must also be maintained for all field equipment used.
Therefore, instrument calibration should be conducted daily for all equip-
ment according to techniques found in the manufacturer's equipment manuals.
Furthermore, all meters should be taken to the laboratory for quarterly
maintenance, calibration, and quality control checks. Field equipment
should be labeled to indicate the calibration date, the calibration expira-
tion date, and the date when maintenance is due. Any equipment malfunction
discovered in the field should be immediately tagged in the field.
H. DOCUMENTATION
All information pertinent to a field survey and/or sampling will be
recorded by the inspector in three forms: field notebook, checklists, and
photographs. Proper documentation and document control are crucial to the
enforcement system since the government's case in a formal hearing or crimi-
nal prosecution often hinges on the evidence gathered by the Inspector.
Therefore, it 1s Imperative that each inspector keep detailed records of
inspections, investigations, photographs taken, etc. and thoroughly review
ill 1 notes before leaving the site.
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The purpose of document control is to assure that all documents for a
specific inspection are accountable when the inspection is completed.
Accountable documents include items such as logbooks, field data records,
correspondence, sample tags, graphs, chain-of-custody records, bench cards,
analytical records, and photos. To insure proper document control, each
document should bear a serialized number and should be listed, with the
number, in a project document inventory assembled at the inspection's com-
pletion. Waterproof ink should be used in recording all data on serialized
accountable documents.
1. Field Notebook
In keeping field notes, each inspector should maintain a legible daily
diary containing an accurate and inclusive documentation of all inspection
activity, conversations, and observations. This will include any comments
as well as a record of sampling points, photograph points, and areas of
potential violation. Since the diary will form the basis for later written
reports, it must contain only facts and observations. Language should be
objective, factual, and free of personal feelings or other terminology which
might prove inappropriate. Field notes and observations should be main-
tained in a bound, consecutively numbered notebook. These data will also
serve as an aid to giving testimony. Furthermore, the diary is a part of
EPA's regional files and should not be considered the inspector's personal
record.
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9938.2
2. Checklists
Checklists, the second method of documentation, should be used in con-
junction with the field notes. A series of checklists has been included in
%he next section for use by the inspector to insure that all necessary areas
of concern are reviewed during the inspection (see Figures 10-20). These
checklists should be used as tools for ensuring a comprehensive review, but
should not be used as substitutes for judgment. After the inspection,
checklists may also be copied and left for owner/operators to inform them of
inspection results, particularly in those areas indicating potential viola-
tions.
3. Photographs
Photographs are the most accurate demonstration of the inspector's
observations. They can be significant and informative to the inspector for
review during future inspections, at informal meetings, and hearings.
'Documentation of a photograph is crucial to its validity as a representation
of an existing situation. Therefore, for each photograph taken, several
•items subsequently should be noted in the inspector's field notebook:
a. date;
b. time;
c. type of film, lens, and camera used;
d. photographed by (signature);
e. name and ID number of site;
f. general direction faced;
g. location of checkpoint on site; and
h. other comments (e.g., weather conditions).
Comments should be limited because any discussion of the photograph in
terms of its contents could jeopardize its value as evidence.
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The type of camera used by the inspector is optional. However, single
lens reflex and/or Polaroid-type cameras are useful. Inspectors should also
be aware that it is possible that photographs taken with a telephoto lens
may not be admissabl* evidence.
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9938.2
When reviewing checklists and field notes before leaving the facility,
the inspector may wish to point out potential deficiencies in facility
maintenance and operation. Copies of the inspection checklist could subse-
quently be left with the facility operator and could be effective in encour-
aging compliance.
B. REPORT PREPARATION
Clear, accurate reporting is essential to the Inspection and Enforce-
ment System. It is the basis for important administrative decisions con-
cerning program effectiveness, enforcement actions, and the proper program-
ming of future work. The Compliance Inspection report should be completed
as soon after the inspection as practicable, using information logged in the
field. The inspector should be brief, thoroughly objective and factual. He
should not report trivial episodes unrelated to the inspection. It must be
remembered that the entire report may be introduced as evidence in a court
case.
Inspectors should complete an inspection report in a format such as the
one shown in Figure 9 or compose a narrative according to the format estab-
lit hed in the report form. All reports ntist contain the facility number,
facility name, inspector and date of Inspection. Field notes, checklists,
and photographs should be carefully reviewed and used to supplement the
narrative where appropriate. Any attachments should be noted In the report.
AVI Inspection violations must be documented in the Inspection report. All
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9978.2
reports must be completed as if they will lead to enforcement action. In
some Regions, checklists may be submitted as inspection reports in which
case guidelines for information content and attachments still apply.
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FIGURE 9
9938.2
RCRA COMPLIANCE INSPECTION REPORT FORMAT
1. Facility Information:
2. Responsible Official:
3. Survey Participants:
4. Date of Inspection:
5. Applicable Regulations:
6. Purpose of Survey:
7. Facility Description:
(Name, Address, Telephone).
(Name, Title)
(Name, Agency or Company)
40 CFR Parts 260-265 (FR February 26 and
Hay 19, 1980).
(Requested By, Inspection Of, Sampling Of.
etc.).
(RCRA Related Activities).
When Inspecting Generators:
8. General Standards for
Generators:
9. The Manifest:
10. Pretransport Requirements:
11. Recordkeeping and
Reporting:
12. Special Conditions:
262.10 - 262.12 (Describe compliance with
these standards).
262.20 - 262.23 (Establish existence of
manifest records, assess adequacy with
regulatory requirements).
262.30 - 262.34 (Review packaging, label-
ing, marking and placarding procedures
for compliance with the regulations.
Establish compliance with accumulation
time restrictions).
262.40 - 262.43 (Establish existence of
annual reports and additional reports.)
262.50 - 262.51 (Inspect for reports of
International shipments of waste, and
proper notification to the Administrator).
When Inspecting Transporters
13. General:
263.10 - 263.11 (Ensure that the trans-
porter has obtained an EPA 1.0. number).
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FIGURE 8 - Continued
14. Manifest System and
Record'neeping:
15. Hazardous Waste Dis-
charges:
263.20 - 263.22 (Establish existence of
manifest records and compliance with
manifest procedures).
263.30 - 263.31 (Ensure the transporter
is aware of the responsibilities of this
section. Check to see if any discharge
reports have been reported to the Depart-
ment of Transportation as required by
these regulations).
When Inspecting Facilities
16. General Facility
Standards:
17. Preparedness and
Prevention:
18. Contingency Plan and
Emergency Procedures:
19. Manifest System, Record-
keeping and Reporting:
20. Groundwater Monitoring:
21. Closure and Post
Closure:
22. Facility Specific
Standards:
265.10 - 265.17 (Describe compliance with
these standards).
265.30 - 265.37 (Check for required equip-
ment and arrangements with local authori-
ties).
265.50 - 265.69 (Check records and proce-
dures for adequacy with requirements of
this section).
265.70 - 265.77 (Establish existence of
manifest records, operating record, annu-
al report and unmanifested waste report.
Assess adequacy with regulatory require-
ments).
265.90 - 265.94 (Examine groundwater mon-
itoring plan and review results of sampling
analysis).
265.110 - 265.120 (Review closure and post
closure plan for adequacy with regulatory
requirements).
265.170 - 265.430 (Depending upon the
type of facility being Inspected estab-
lish compliance with the appropriate
regulatory standards).
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FIGURE 8 - Continued 9938.2
23. Documentation of
Violation: (Summarize violations listed above with
quotes from applicable regulations).
24. Recommendations: (To bring facility Into compliance).
25. State Coordination: (Assisted by, copy of report to, addi-
tional information obtained from).
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VII. TYPES OF FACILITIES
A. OBJECTIVE
Subtitle C of RCRA calls for governmental regulation and systematic
control of the generators and transporters of hazardous waste and of owners
and operators of hazardous waste treatment, storage, and disposal facili-
ties. Outlined in this chapter are the regulatory requirements pertaining
to inspections, the inspection procedures to be followed for each require-
ment, the necessary documentation for potential violations, and the appro-
priate sampling points for each type of facility. Subtitle C covers gener-
ators, and transporters, plus the following facilities: tanks, surface
impoundments, waste piles, land treatment facilities, landfills, incinera-
tors, thermal treatment facilities, chemical, physical, and biological
treatment facilities, and underground injection facilities.
Regulatory requirements addressed in this manual cover Identification
requirements, maintenance and monitoring requirements, and closure and
post-closure requirements. Identification requirements pertain to hazardous
waste labeling and recordkeeping. Maintenance requirements include general
housekeeping and structure integrity. Monitoring requirements include
records of monitoring as well as maintenance of monitoring equipment.
Closure and post-closure requirements deal with proper closing and monitor-
ing of non-operating sites.
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99 ^R
B. REGULATIONS AND PROCEDURES "JO.
This chapter, presents a table of the regulatory requirements that must
be addressed in a compliance inspection (Table 3). For each requirement,
the appropriate inspection procedures and documentation procedures are
delineated. This chapter also contains a series of checklists (Figures
10-20) one for each type of hazardous waste handler covered in Subtitle C
(generators, transporters, tanks, surface impoundments, waste piles, land
treatment facilities, landfills, incinerators, thermal treatment facilities,
chemical, physical, and biological treatment facilities, and underground
injection facilities). Inspectors may utilize these checklists, as well as
checklists for administrative information pertaining to all facilities, as
outlines or final checks for their inspections. Upon determining the types
of operations permitted at a particular facility, the inspector will be able
to decide which checklists will be appropriate for any given inspection.
The original checklists can be removed from the manual and copied for field
inspections. As items on the checklists are covered during an inspection,
they may be checked off immediately, and supplementary notes may be included
in the inspector's field diary, or items may be checked off subsequent to
the inspection as a review of all mandated checkpoints. Checkpoints that
nay require some evaluation .are followed by a space and checkpoints requir-
ing only acknowledgement are followed by checking yes or no.
Both Table 3 and Figures 10-20 reflect Phase I of the RCRA regulatory
program. (Regulations of May 19, 1980 and subsequent amendments.) The
table and figures will be updated as the Phase I regulations are revised.
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C. INSPECTION PROCEDURES FOR NON-NOTIFIERS
Inspections may be conducted to determine whether handlers of hazardous
waste who have not notified under §3010 of RCRA should have done so. Steps
that should be taken by the inspector to make this determination include the
following:
1. Request proof of a non-hazardous determination (this applies
to generators) via written notice or site visit.
2. If the generator is unable to satisfactorily demonstrate how
such a determination was made, ask the generator to present
data or records indicating the following:
materials used and their quantity
processes used
product output and quantity of output
wastestream produced and quantity
by-products created and quantity.
3. Evaluate the data to determine whether or not the gener^icr
produces hazardous waste in quantities regulated by the Act..
4. If doubt still exists concerning the nature of the waste-
stream, take a representative sample of the wastestream and
submit it for analysis.
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o.
TABLE 3
REGULATORY REQUIREMENTS
INSPECTION PROCEDURE
DOCUMENTATION
GENERATORS
§262.12 EPA Identification Numbers.
(a) A generator nust not treat, store.
dispose of, transport, or offer for trans-
portation, hazardous waste without having
received an EPA identification number from
the Administrator.
(c) A generator must not offer his haz-
ardous waste to transporters or to treat-
ment, storage, or disposal facilities that
have not received an EPA identification
nunber.
S262.20 General Requirements.
(a) A generator who transports, O(r
offers for transportation, hazardous
waste for off-site treatment, storage.
or disposal Bust prepare a Manifest
before transporting the waste off-site.
S262.30 Packaging.
(a) Hazardous waste containers oust meet
DOT standards as specified In 49 CFR 173.
178 and 179.
Check for generator, transporter,
and TSD identification numbers.
check wastes deemed not hazardous to
assure compliance. Sample if necessary.
Document non-compliance in
field book.
Check outgoing shipments for (1)
presence of document and (2) inclusion
of all information specified in
Attachment A.
Examine for leaks and corroding con-
tainers. Use pH paper or meter near
drum.
Document any Inadequacies.
Copy manifests.
Note evidence of leakage or
corrosion. Photograph.
•Requirements are numbered according to the ;Kules and Kegulatious of May 19. 1980. Because not all requirements of the
Rules and Regulations have been addressed in this fable, there are gaps in the consecutive numbering. . Items not addressed
are those that are not verifiable by inspection or sampling, or that apply to facility siting and design rather than con-
struction, operation or maintenance.
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REGULATORY REQUIREMENTS
INSPECTION PROCEDURE
DOCUMENTATION
§262.31 Labeling.
Before transporting or offering
hazardous waste for transportation off-
site, a generator oust label each package
in accordance with the applicable Depart-
ment of Transportation regulations on
hazardous materials under 49 CFR Part 172.
§262.32 Narking.
(a) Before transporting or offering
hazardous waste for transportation off-
site, a generator Bust mark each package
of hazardous waste in accordance with the
applicable Department of Transportation
regulations on hazardous naterials under
49 CFR Part 172.
(b) Before transporting hazardous waste
or offering hazardous waste for transporta-
tion off-site, a generator oust nark each
container of 110 gallons or less used in
such transportation with the following
words and information displayed in accord-
ance with the requirements of 49 CFR 172.304:
HAZARDOUS WASTE—Federal Law Prohibits
Improper Disposal. If found, contact the
nearest police or public safety authority or
the U.S. Environmental Protection Agency.
Generator's Name and Address _.
Manifest Document Number
Check whether all labeling and
marking is in accordance with DOT
regulations under 49 CFR Part 172.
Check whether all labeling and
marking is in accordance with DOT
regulations under 49 CFR Part 172.
Document non-compliance.
Photograph.
Document non-compliance.
Photograph.
Check thai each container of 110 gallons
or less used for transport complies with
4*J CFR 172.304.
Document non-compliances.
Photograph.
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K)
REGULATORY REQUIREMENTS
INSPECTION PROCEDURE
DOCUMENTATION
§262.33 Placarding.
Before transporting hazardous waste or
offering hazardous waste for transporta-
tion off-site, a generator oust placard
or offer the initial transporter the
appropriate placards according to Depart-
ment of Transportation regulations for
hazardous materials under 49 CFR Part 172,
Subpart f.
§262.34 Accumulation Tine.
(a) A generator may accumulate hazardous
waste on-site without a penait for 90 days
or less, provided that:
(1) All such waste is shipped off-
site In 90 days or less;
(2) The waste is placed in containers
which meet the standards of §26?.30 and
are managed in accordance with 40 CFR
265.174 and 265.176 or in tanks, provided
the generator complies with the require-
acts of Subpart J of 40 CFR Part 26S
except §265.193;
(3) The date upon which each period of
accumulation begins is clearly marked and
visible for inspection on each container;
(4) Each container is properly labeled
and marked according to §262.31 and
§262.32; and
Check that hazardous waste to be trans-
ported is placarded according to 49 CFR
172, Subpart F.
Check that accumulation of waste is for
less than 90 days (check records or
dates on containers).
Clieck that accumulating wastes are in
containers in accordance with
49 CFR 173. 170, 1/9 (DOT Regs, for
shippers, container specs, tank car
specs) and managed in accordance with
49 CFR 265.174 and 265.176, or tanks
in accordance with 40 CFR Part 265
(subpart J).
Check each container for a date and
proper label.
Doc ument non-comp1i ances.
Photograph.
Document non-compliance. Obtain
copy of records. Document any
inadequacies in waste containment.
Photograph.
Document (locate and identify)
containers not labeled properly.
Photograph.
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REGULATORY REQUIREMENTS
INSPECTION PROCEDURE
DOCUMENTATION
(5) The generator complies with the
requirements for owners or operators in
Subparts C and D in 40 CFR Part 265 and
with §265.16.
(b) A generator who accumulates hazardous
waste for more than 90 days is an operator
of a storage facility and is subject to
the requirements of 40 CFR Parts 264 and
265 and the permit requirements of 40 CFR
Part 122.
§262.40 Recordkeep i ng.
(a) A generator must keep a copy of
each manifest signed in accordance with
§262.23(a) for three years or until he
receives a signed copy from the designated
facility which received the waste. This
signed copy must be retained as a record for
at least three years from the date the waste
was accepted by the Initial transporter.
Check for compliance with 40 CFR
Part 265 and with personnel training
requirements, preparedness and pre-
vention procedures and presence of a
contingency plan and emergency
procedures. Also review records to
see if there have been instances where
the contingency plan was put into
effect. If so. ensure that an
Emergency Incident Report is also
present and was sent to the Regional
Office.
Check for a permit to operate a
storage facility. Refer to 40 CFR
264 and 265 and 40 CFR Part 122.
Document non-compliance.
Check for presence of records:
- Copies of manifests and/or signed
copies from designated facilities;
- Annual Reports (EPA forms 8700-13
and 8700-13A);
- Exception Reports (includes copy of
manifest and letter of explanation);
- Records of test results, waste
analyses and other determinations.
Document non-compliance or availabil-
ity of a permit.
Document inadequacies in record-
keeping. Obtain sample copy of
records.
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CD
REGULATORY REQUIREMENTS
INSPECTION PROCEDURE
DOCUMENTATION
(b) A generator must keep a copy of each
Annual Report and Exception Report for a
period of at least three years from the due
date of the report (March 1 for Annual
Report).
(c) A generator must keep records of any
test results, waste analyses, or other
determinations made in accordance with
§262.11 for at least three years fron the
date that the waste was last sent to on-
site or off-site treatment, storage, or
disposal.
§262.50 International Shipments.
(a) Any person who exports hazardous
waste to a foreign country or imports
hazardous waste from a foreign country
into the United States must comply with
the requirements of this Part and with
the special requirements of this section.
(b) When shipping hazardous waste outside
the United States, the generator must:
(1) Notify the Administrator in writing
four weeks before the initial shipment of
hazardous waste to each country in each
calendar year;
(2) Require that the foreign consignee
confirm the delivery of the waste in the
Check for exporting and/or importing
of wastes to/from foreign countries.
Check for copy of letter of Notifica-
tion to Administrator or any evidence
of notification.
Check manifests for required
information. Check for copies of
Document non-compliance.
Document inadequacies in manifests.
Obtain sample copy.
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REGULATORY REQUIREMENTS
INSPECTION PROCEDURE
DOCUHENTATION
foreign country. A copy of the manifest
signed by the foreign consignee may be
used for this purpose;
(3) Meet the requirements under §262.21
for the manifest, except that:
(i) In place of the name, address, and
EPA identification number of the designated
facility, the name and address of the
foreign consignee must be used;
(il) The generator must identify the point
of departure from the United States through
which the waste must travel before entering
a foreign county.
(c) A generator must file an Exception
Report, if:
manifest signed by foreign
consignee.
Check for confirmation of delivery of
shipments or copy ot Exception Reports.
Document non-compliance.
(1) He has not received a copy of the
manifest signed by the transporter stating
the date and place of departure from the
United States within 45 days from the date
It was accepted by the Initial transporter; or
(2) Within 90 days from the date the waste
was accepted by the initial transporter, the
generator has not received written confirma-
tion from the foreign consignee that ,the
hazardous waste was received.
(d) When importing hazardous waste, a
person must meet all requirements of
For imported hazardous wastes, check
manifest for required information:
Document inadequancies in
manifests. Copy manifests.
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§262.21 for the manifest except that:
(1) In place of the generator's name,
address and EPA identification number,
the name and address of the foreign
generator and the importer's name,
address and EPA identification number
must be used; and
(2) In place of the generator's signa-
ture on the certification statement, the
U.S. importer or his agent must sign and
date the certification and obtain the
signature of the initial transporter.
TRANSPORTERS
S263.ll EPA Identification Number.
(a) A transporter must not transport
hazardous wastes without having received
an EPA identification number from the
Administrator.
§263.12 Transfer Facility Requirements
(a) A Transporter who stores manifested
shipments of hazardous waste in containers
meeting the requirements of 262.30 for a
period of 10 days or less is not subject
to regulation under Parts 122, 264, or 265.
Importer's name;
Importer's EPA I.D. number;
Names and Address of foreign
generator;
Signatures of U.S. importer and
initial transporter.
Check for transporter identification
number. Make direct observation (on
manifest, delivery document or hazardous
incident report). Check license number.
Check current date on Lag.
If the transporter has wastes stored
on site, check the manifest accompany-
ing the waste to establish the lemjth
of time the waste lids been stored. If
stored for more than 10 days, check
that the transporter has complied with
Document non-compliance in field
book.
Document length of time waste has
been stored.
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§263.20 The Manifest System.
(a) A transporter nay not accept
hazardous waste from a generator unless
It is accompanied by a manifest and signed
by the generator in accordance with the
provisions of 40 CFR Part 262.
(b) Before transporting the hazardous
waste, the transporter must sign and date
the manifest acknowledging acceptance of
the hazardous waste from the generator.
The transporter must return a signed copy
to the generator before leaving the
generator's property.
(c) The transporter must ensure that the
manifest accompanies the hazardous waste.
(d) A transporter who delivers a hazard-
ous waste to another transporter or to the
designated facility must:
(1) Obtain the date of delivery and the
handwritten signature of that transporter
or of the owner or operator of the
designated facility on the manifest;
(e) The requirements of paragraphs (c).
(d) and (f) of this section do not apply
to water (bulk shipment) transporters if:
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Parts 122. 264 and 265 for hazardous
waste facilities.
Check for presence of document at
transfer stations.
Check document for signatures.
Check for signed copy returned
by transporter.
Document non-compliance.
Check for manifest at transfer
stations.
Document non-compliance. Obtain
copy of document if possible.
Check for copies of all manifests.
Check manifest for signatures.
For shipments by water (bulk shipment)
check that transporter has:
- A shipping paper accompanying the
waste.
VI1-11
Document non-compliance. Obtain
copy if manifest is incomplete.
Document non-compliance. Obtain
copy of shipping paper if
incomplete.
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(1) The hazardous waste Is delivered
by water (bulk shipment) to the
designated facility; and
(2) A shipping paper containing all the
Information required on the manifest
(excluding the EPA identification numbers.
generator certification, and signatures)
accompanies the hazardous waste; and
(3) The delivering transporter obtains
the date of delivery and handwritten signa-
ture of the owner or operator of the desig-
nated facility on either the manifest or
the shipping paper;
(4) The person delivering the hazardous
waste to the initial water (bulk shipment)
transporter obtains the date of delivery
and signature of the water (bulk shipuienl)
transporter on the manifest and forwards
it to the designated facility; and
(5) A copy of the shipping paper or
oanifest is retained by each water (bulk
shipment) transporter in accordance with
§263.22.
(f) For shipments involving rait trans-
portation the requirements of paragraphs
(c), (d), and (e) do not apply and the
following requirements do apply:
The date of delivery and signature of
the designated facility on the manifest
or the shipping paper.
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(1) When accepting hazardous waste from
a non-rail transporter, the initial rail
transporter oust:
(i) Sign and date the manifest
acknowledging acceptance of the hazardous
waste;
(ii) Return a signed copy of the mani-
fest to the non-rail transporter;
(iii) Forward at least three copies of
the manifest to:
[A] The next non-rail transporter, if
any; or,
[B] The designated facility, if the
shipment is delivered to that facility
by rail; or
[CJ The last rail transporter desig-
nated to handle the waste in the United
States;
(iv) Retain one copy of the manifest and
rail shipping paper in accordance with
§263.22.
(2) Rail transporters must ensure that a
shipping paper containing all the informa-
tion required on the manifest (exluding
the EPA identification numbers, generator
certification, and signatures) accompanies
the hazardous waste at all times.
Check to verify the maintenance of the
manifest or shipping paper with appro-
priate signature and date of acceptance.
Document non-compliance and record
missing records. Obtain copy of
shipping paper if incomplete.
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(3) When delivering hazardous waste to
the designated facility, a rail trans-
porter oust:
(i) Obtain the date of delivery and
handwritten signature of the owner or
operator of the designated facility
on the manifest or the shipping paper
(if the manifest has not been received
by the facility); and
(11) Retain a copy of the manifest
or signed shipping paper in accordance
with §263.22.
(4) When delivering hazardous waste
to a non-rail transporter a rail trans-
porter must:
(1) Obtain the date of delivery and the
handwritten signature of the next non-rail
transporter on the manifest; and
(II) Retain a copy of the manifest in
accordance with §263.22.
(5) Before accepting hazardous waste
from a rail transporter, a non-rail
transporter must sign and dale the mani-
fest and provide a copy to the rail
transporter.
(g) Transporters who transport hazardous
waste out of the United States must:
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Check to ensure papers are retained
and contain the required information.
uocufient Rcn-coapJiance.
For export of hazardous waste shipments, Document non-compliance. Obtain
check for copies of each manifest. copy of manifest if incomplete.
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(1) Indicate on the manifest the date
the hazardous waste left the United
States; and
(2) Sign the manifest and retain one
copy In accordance with §263.22(c); and
(3) Return a signed copy of the mani-
fest to the generator.
§263.22 Recordkeeplng.
(^ A transporter of hazardous waste
must keep a copy of the manifest signed
by the generator, himself, and the next
designated transporter or the owner or
operator of the designated facility for
a period of three years from the date the
hazardous waste was accepted by the
initial transporter.
(b) For shipments delivered to the
designated facility by water (bulk
shipment), each water (bulk shipment)
transporter must retain a copy of a
shipping paper containing all the
information.
(c) For shipments of hazardous waste
by rail within the United States:
(i) The initial rail transporter
must keep a copy of the manifest and
shipping paper with all the information
Check for inclusion of date of export
and appropriate signatures.
Check for copy of manifest or
shipping paper. Check dates of
documents and signatures.
Document non-compliance in
field book.
Check for copy of shipping paper.
Check dales and signatures.
Document non-compliance.
Check for copies of manifest or ship-
ping paper. Check dales of documents
and signatures.
Document non-compliance.
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required In §263.20(f)(2) for a period
of three years from the date the hazardous
waste was accepted by the intia) trans-
porter; and
(11) The final rail transporter Must
keep a copy of the signed manifest (or
the shipping paper if signed by the
designated facility in lieu of the mani-
fest) for a period of three years from
the date the hazardous waste was accepted
by the initial transporter.
FACILITIES
Subpart B - General Facility Standards
§ 265.12 Required Notices.
(a) The owner or operator of a facility
that has arranged to receive hazardous
waste from a foreign source must notify
the Regional Administrator in writing at
least four weeks in advance of the date
the waste is expected to arrive at the
facility. Notice of subsequent shipments
of the sane waste from the same foreign
source is not required.
S265.13 General Waste Analysis.
(a)O) Before an owner or operator
treats, stores, or disposes of any
hazardous waste, he must obtain a
7/24/81
Check facility compliance file for
record of notices.
Document evidence of non-compliance.
Check records for any waste analyses
performed. Inquire about frequency of
detailed waste sampling. Check for
VII-16
Document any inadequacies in
records. Document inadequacies
or unavailability of waste
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detailed chemical and physical analysis
of a representative sample of the waste.
At a minimum, this analysis oust contain
all the information which must be known
to treat, store, or dispose of the waste
in accordance with the requirements of
of this Part.
(b) The owner or operator must develop
and follow a written waste analysis plan
which describes the procedures which he
will carry out to comply with paragraph
(a) of this Section. He must keep this
plan at the facility.
§265.14 Security.
The owner/operator must prevent
unknowing entry and have the required
equipment and safety measures in order
to maintain compliance with this section.
availability of a waste analysis plan
and contents (see Attachment B).
Review the waste analysis plan for:
- Test methods;
- Sampling method;
- Frequency of review or repeat analyses.
For off-site facilities, check for the
waste analysis supplied by the generator.
If applicable, review the methods used
to meet additional waste analysis
requirements.
analysis plan.
Inspect for required items (see
Attachment C):
- 24-hour surveillance system;
- An artificial or natural barrier
completely surrounding the active
portion of the facility;
- Gates or other means Lo control entry;
and
- A danger sign at each entrance.
Document inadequacies in
security system. Record and
locate evidence of damage to
equipment. Photograph.
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§265.15 Genera) Inspection Requiresents.
(a) The owner or operator oust inspect
his facility fur nalfunctions and deter-
ioration, operator errors, and discharges
which nay be causing—or nay lead to—•
(1) release of hazardous waste constitu-
ents to the environment or (2) a threat
to human health. The owner or operator
oust conduct these Inspections often enough
to identify problems in time to correct
them before they harm human health or
the environment.
(b)(l) The owner or operator must
develop and follow a written schedule
for inspecting all monitoring equipment.
safety and emergency equipment, security
devices and operating and structural
equipment (such as dikes and sump pumps)
that are important to preventing, detect-
ing, or responding to environmental or
human health hazards.
(2) He oust keep this schedule at the
facility.
(d) The owner or operator must record
inspections in an inspection log or sum-
mary. He must keep these records for at
least three years from the date of
inspection. At a minimum, these records
must include the date and time of the
Inquire about inspection practices of
owner or operator and past detection
of incidents of environmental contam-
ination.
Document evidence of inadequate
inspection practices. Document
past contaminations.
Review schedule for inspection of:
- Monitoring equipment;
- Safety and emergency equipment;
- Security devices; and
- Operating and structural equipment.
(See Attachment D.)
Document items inadequately covered
in inspection schedule.
Review records or log inspections for Document inadequacies in records or
dates, times, inspector's name, observa- inspection log. Obtain copy if
lions and remedial measures. necessary.
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Inspection, the name of the Inspector, a
notation of the observations made, and
the date and nature of any repairs or
other remedial actions.
§265.16 Personnel Training.
(d) The owner or operator must maintain
the following documents and records at the
facility:
(1) The job title for each position at
the facility related to hazardous waste
management, and the name of the employee
filling each job;
(2) A written job description for each
position listed under paragraph (d)(l) of
this Section. This description may be
consistent in its degree of specificity
with descriptions for other similar
positions in the same company location or
bargaining unit, but must include the
requisite skill, education, or other
qualifications, and duties of facility
personnel assigned to each position;
(3) A written description of the type
and amount of both Introductory and con-
tinuing training that will be given to
each person filling a position listed
under paragraph (d)(l) of this section; and
Inspect for the availability and
completeness of documents and records
for personnel. Determine adequacy of
- Job titles;
- Description of training (see
attachment E);
- Records of training.
Document any inadequacies in records.
Obtain copies.
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(4) Records that document that the train-
Ing or job experience required under para-
graphs (a), (b), and (c) of this Section
has been given to, and completed by,
facility personnel.
(e) Training records on current personnel
must be kept until closure of the facility.
Training records on former employees must
be kept for at least three years from the
date the employee last worked at the
facility. Personnel training records may
accompany personnel transferred within the
same company.
§265.17 General Requirements for Ignilable,
Reactive, or Incompatible Wastes.
(a) The owner or operator must take pre-
cautions to prevent accidental ignition or
reaction of ignitable or reactive waste.
This waste must be separated and protected
from sources of Ignition or reaction
Including but not limited to: open flames,
smoking, cutting and welding, hot surfaces,
frictional heat, sparks (static,
electrical, or mechanical), spontaneous
ignition (e.g., from heat-producing
chemical reactions), and radiant heat.
While ignitable or reactive waste is
being handled, the owner or operator must
confine smoking and open flame to
specially designated locations. "No
Check records and inquire about handling
of ignitable, reactive or incompatible
wastes. Inspect for "No Smoking" signs
and general separation and confinement
of these special wastes.
Document inadequacies in records o
handling procedures. Obtain copie
Document and photograph inadequate
confinement and marking.
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Smoking" signs must be conspicuously
placed wherever there 1s a hazard from
ignitable or reactive waste.
(b) Where specifically required by other Inspect for evidence of extreme heat Document evidence of non-
Sections of this Part, the treatment. or pressure (bulging containers). compliance. Photograph.
storage, or disposal of ignitable or re- fire, explosion or fumes. Check
active waste, and the mixture or comming- integrity of waste containers.
ling of Incompatible wastes, or Incompatible
wastes and materials, must be conducted so
that It does not:
(1) Generate extreme heat or pressure,
fire or explosion, or violent reaction;
(2) Produce uncontrolled toxic mists,
fumes, dusts, or gases In sufficient
quantities to threaten human health;
(3) Produce uncontrolled flammable
fumes or gases in sufficient quantities
to pose a risk of fire or explosions;
(4) Damage the structural integrity of the
device or facility containing the waste; or
(5) Through other like means threaten
human health or the environment.
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Subpart C - Preparedness and Prevention
§265.31 Maintenance and Operation of
Facility.
Facilities must be Maintained and opera-
ted to minimize the possibility of a fire,
explosion, or any unplanned sudden or non-
sudden release of hazardous waste con-
stituents to air, soil, or surface water
which could threaten human health or the
environment.
§265.32 Required Equipment.
All facilities must be equipped with
certain equipment unless none of the
hazards posed by waste handled at the
facility could require a particular type
of equipment specified In the regulations.
§265.33 Testing and Maintenance of
Equipment.
All facility communications or alarm
systems, fire protection equipment, spill
control equipment, and decontamination
Inspect for evidence of fire.
explosion, or contamination of
environment due to the release
of hazardous waste.
Document evidence of improper
maintenance or operation.
Photograph.
Inspect for the presence of required
equipment: or equipment maintenance.
- Alarm system or internal communi-
cations system accessible to all
personnel;
- Telephone or 2-way radio for
summoning emergency assistance;
- Portable fire extinguishers and
fire control, spill control and
decontamination equipment; and
- Water of adequate volume for hoses
spinklers, or water spray system.
Inquire about testing and maintenance
practices of facility. Check
operating condition of equipment.
Document inadequacies in equipmen
Document inadequate maintenance
or testing.
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equipment, where required, must be tested
and maintained as necessary to assure its
proper operation in time of emergency.
§265.35 Required Aisle Space.
The owner or operator must maintain
aisle space to allow the unobstructed
movement of personnel, fire protection
equipment, spill control equipment, and
decontamination equipment to any area
of facility operation in an emergency,
unless aisle space is not needed for
any of these purposes.
§265.37 Arrangements with Local Authorities.
(a) The owner or operator must attempt to
make the following arrangements, as
appropriate for the type of waste handled
at his facility and the potential need
for the services of these organizations:
(1) Arrangements to familiarize police,
fire departments, and emergency response
teams with the layout of the facility,
properties of hazardous waste handled at
the facility and associated hazards,
places where facility personnel would
normally be working, entrances to roads
Inside the facility, and possible
evacuation routes;
Inspect for adequate aisle space.
Document inadequacy. Photograph.
Inspect operating record for
appropriate arrangements with
necessary organizations: (police,
fire departments, emergency
response teams, equipment suppliers,
local hospitals) or for refusal of
arrangements by organizations.
Document Inadequacies in- local
arrangements.
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(2) Where note than one police and fire
department night respond to an emergency,
agreements designating primary emergency
authority to a specific police and a
specific fire department, and agreements
with any others to provide support to the
primary emergency authority;
(3) Agreements with State emergency
response teams, emergency response
contractors, and equipment suppliers; and
(4) Arrangements to familiarize local
hospitals with the properties of hazardous
waste handled at the facility and the
types of injuries or illnesses which
could result from fires, explosions,
or releases at the facility.
(b) Where State or local authorities
decline to enter into such arrangements,
the owner or operator must document the
refusal in the operating record.
Subpart D - Contingency Plan and Emergency Procedures
§265.52 Content of Contingency Plan.
§265.53 Copies of Contingency Plan.
A copy of the contingency plan and all
revisions to the plan must be:
Check contingency plan for all
required Hems. See Attachment F.
Check for availability of contingency
plait and distribution to local
authorities.
Document lack of contingency plan
or inadequacies in content. Oblai
copies.
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(a) Maintained at the facility; and
(b) Submitted to all local police
departments, hospitals, and State and
local emergency response teams that
may be called upon to provide emergency
services.
§265.55 Emergency Coordinator.
At all times, there must be at least one
employee either on the facility premises
or on call(i.e., available to respond to
an emergency by reaching the facility
within a short period of time) with the
responsibility for coordinating all
emergency response measures.
§265.56 Emergency Procedures.
The owner or operator must note in the
operating record the time, date, and
details of any incident that requires
implementing the contingency plan.
Within 15 days after the Incident he
must submit a written report on the
incident to the Regional Administrator.
Ask for identification of an emergency
coordinator on-site. Check his
familiarity with the emergency pro-
cedures and ability to carry out
the contingency plan.
Document inadequacies in
emergency coordinator's
preparedness.
Check records for incidences of
implementing the contingency plan.
Check for submission of written
reports to RA.
Document inadequate operating
records. Obtain copies.
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Subpart E--Man1fest System. Recordkeeping.
and Reporting
§265.71 Use of Manifest System.
If a facility receives hazardous waste
accompanied by a manifest, or shipping
paper the owner or operator must process
that manifest in accordance with §265.71.
(5) The owner or operator must retain
at the facility a copy of each Manifest
or shipping paper for at least three
years from the date of delivery.
§265.72 Manifest Discrepancies.
(a) Manifest discrepancies are differ-
ences between the quantity or type of
hazardous waste designated on the manifest
or shipping paper, and the quantity or
type of hazardous waste a facility
actually receives. Significant dis-
crepancies In quantity are: (1) for
bulk waste, variations greater than 10
percent in weight, and (2) for batch
waste, any variation In piece count, such
as a discrepancy of one drum In a truck load.
Significant discrepancies in type are
obvious differences which can be dis-
covered by inspection or waste analysis,
such as waste solvent substituted for
waste acid, or toxic constituents not
reported on the manifest or shipping paper.
Inquire about procedures used in
processing each manifest.
Check records for copies of
manifests for past shipments.
Document evidence of improper
manifest procedures.
Document inadequacies in records.
Inquire about practices used to
detect descrcpancies in shipments
(10% of weight for bulk waste or
variation in piece count for batches):
inspections, waste analyses, etc.
Document inadequacies or lack
of discrepancy detection pro-
cedures.
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§265.73 Operating Record.
(a) The owner or operator must keep a
written operating record at his facility.
§265.74 Availability, Retention, and
Disposition of Records.
(a) All records. Including plans.
required under this Part must be
furnished upon request, and made
available at all reasonable times for
inspection, by any officer, employee,
or representative of EPA who is duly
designated by the Administrator.
§265.75 Annual Report.
The owner or operator must prepare
and submit a single copy of an annual
report to the Regional Administrator by
March 1 of each year. The report form
and instructions In Appendix II of RCRA
§265 must be used for this report. The
annual report must cover facility
activities during the previous calendar year.
§265.76 Unmanifested Waste Report.
If a facility accepts for treatment,
storage, or disposal any hazardous waste
from an off-site source without an
accompanying manifest, or without an
Check for presence and maintenance
of operating records. Records must
include items listed in Attachment G.
Check for presence and maintenance
of records and plans.
Check for preparation of annual
reports and submittal to RA. Check
facility compliance file for annual
reports.
Document inadequacies in operalin
record. Obtain copies, if
necessary.
Document inadequacies in records
and plans.
Document inadequacies in
procedure.
Note that this requirement does not take effect until March 1, 1982.
Check for procedures used for
unmanifested wastes, i.e., report
and submiltal to RA. Check facility
compliance file for reports.
Document inadequacies in procedur
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accompanying shipping paper as described
in §263.20{e)(2) of this Chapter, and if
the waste Is not excluded from the mani-
fest requirement by §261.5 of this Chapter.
then the owner or operator must prepare and
submit a single copy of a report to the
Regional Administrator within 15 days after
receiving the waste. The report form and
instructions in Appendix II must be used
for this report.
§265.77 Additional Reports.
In addition to submitting the annual
report and unnaniTested waste reports
described In §§265.75 and 265.76, the
owner or operator must also report to
the Regional Administrator:
(a) Releases, fires, and explosions as
specified in § 265.56(j);
(b) Ground-water contamination and
monitoring data as specified in §§265.93
and 265.94; and
(c) Facility closure as specified In
§265.115.
Check facility compliance file
for reports.
Document discrepancies in file.
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Subpart F - Ground-Water Monitoring
§265.90 Applicability.
(b) Except as paragraphs (c) and (d) of
this Section provide otherwise, the owner
or operator oust install, operate, and
maintain a ground-water monitoring system
which meets the requirements of §265.91,
and must comply with §§265.92-265.94.
This ground-water monitoring program
must be carried out during the active
life of the facility, and for disposal
facilities, during the post-closure
care period as well.
(c) All or part of the ground-water
monitoring requirements of this Subpart
may be waived if the owner or operator can
demonstrate that there is a low potential
for migration of hazardous waste or
hazardous waste constituents from the
facility via the uppermost aquifer to water
supply wells (domestic, industrial, or
agricultural) or to surface water. This
demonstration must be In writing, and must
be kept at the facility. This demonstra-
tion must be certified by a qualified
geologist or geotechnical engineer.
§265.91 Ground-Water Monitoring System.
(a) A ground-water monitoring system
must be capable of yielding ground-water
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Check operation and maintenance
of a ground-water monitoring
system or written demonstration
of a waiver of the requirement
(certified by a geologist or
engineer).
Document inadequacies in system
or uncertified waiving of a re-
quirement.
Inspect for presence of required
monitoring wells.
VII-29
Document inadequacies in
monitoring system.
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samples for analysis and consist of:
- At least one monitoring well upgradlent;
- At least three monitoring wells down-
gradient.
(b) Separate monitoring systems for each
waste management component of a facility
are not required provided that provisions
for sampling upgradient and downgradient
water quality will detect any discharge
from the waste management area.
(c) All monitoring wells must be cased
in a manner that maintains the integrity
of the monitoring well bore hole. This
casing must be screened or perforated,
and packed with gravel or sand where
necessary, to enable sample collection
at depths where appropriate aquifer flow
zones exist. The annular space (i.e.,
the space between the bore hole and well
casing) above the sampling depth must be
sealed with a suitable material (e.g.,
cement grout or bentonite slurry) to pre-
vent contamination of samples and the
ground water.
§265.92 Sampling and Analysis.
(a) The owner or operator must obtain
and analyze samples from the Installed
ground-water monitoring system. The
owner or operator must develop and
follow a ground-water sampling and
Determine whether number and place-
ment of wells are sufficient for
management area.
Check for continued maintenance of
wells and integrity of:
- Casing and backfilling (e.g.
evidence of cracking)
- Annular space;
- Bore hole (evidence of
percolation); and
- Cap over well opening.
Document any inadequacies.
Document any evidence of
insufficient construction or
maintenance.
Check records for sampling and
analysis plan. Review contents
of plan for required items.
Document inadequacies in
sampling and analysis plan.
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analysis plan. He must keep this plan
at the facility. The plan must include
procedures and techniques for:
(1) Sample collection;
(2) Sample preservation and shipment;
(3) Analytical procedures; and
(4) Chain of custody control.
(b) The owner or operator must determine
the concentration or value of the
parameters in ground-water samples in
accordance with paragraphs (c) and (d) of
of this section as listed in Attachment G.
§265.93 Preparation, Evaluation, and
Response.
(a) Within one year after the effective
date of these regulations, the owner or
operator must prepare an outline of a
ground-water quality assessment program.
The outline must describe a more compre-
hensive ground-water monitoring program
(than that described in §§265.91 and
265.92).
Check for sampling and sample
analysis of the ground-water
monitoring system. Sample
analysis should be in compliance
with and include parameters listed
in §265.92(b).(c). and (d) (see
Attachment H. Review records for
background levels, periodic ground-
water quality, and elevation of
ground water surface.
Check integrity of facility's
analyses by sampling and analysis.
Check for adequacy of ground-water
quality assessment program. Program
must include items listed in
Attachment 1.
Document inadequacies in or lack
of sampling and analysis practice
Obtain copy of records of analysi
Record sample location. Label
containers. Leave sample receipt
Document inadequacies in program.
Obtain copies.
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§265.94 Recordkeeping and Reporting.
(a) Unless the ground water is
monitored to satisfy the requirements of
§265.93(d)(4). the owner or operator
must:
(1) Keep records of the analyses
required In §265.92(c) and (d). the
associated ground-water surface
elevations required in §265.92(e), and
the evaluations required in §265.93(b)
throughout the active life of the facility.
and, for disposal facilities, throughout
the post-closure care period as well; and
(2) Report ground-water monitoring informa-
tion to the Regional Administrator.
(b) If ground-water is monitored to
satisfy the requirements of §265.93(d)(4).
the owner or operator must:
(1) Keep records of the analyses and
evaluations specified in the plan, which
satisfies the requirements of §265.93(d)(3),
throughout the active life of the facility,
and throughout the post-closure care period
as well; and
(2) Annually, until final closure of the
facility, submit to the Regional
Administrator a report containing the
results of his ground-water quality
Check records for analyses of back-
ground levels, periodic sampling,
surface elevations, and all required
calculations. See Attachment I.
Document inadequacies in records.
Obtain copies.
Check records for required
analyses listed in Attachment 1.
Document inadequacies in records.
Obtain copies.
Check facility compliance file
for annual reports of ground-
water quality assessment program.
Document inadequacies or discrep-
ancies incompliance file.
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assessment program which Includes, but
is not limited to, the calculated (or
measured) rate of migration of hazardous
waste or hazardous waste constituents in
the ground water during the reporting
period. This report must be submitted as
part of the annual report required under
§265.75.
Subpart G—Closure and Post-Closure
§265.112 Closure Plan; Amendment of Plan.
(a) By May 19, 1981, the owner or
operator must must have a written
closure plan. He must keep a copy of the
closure plan at the facility until closure
is completed and certified in accordance
with §265.115. This plan must identify
the steps necessary to completely or par-
tially close the facility at any point
during Its intended operating life and
to completely close the facility at the
end of its Intended life.
(c) The owner or operator must submit
his closure plan to the Regional
Administrator at least 180 days before
the date he expects to begin closure. The
ownr or operator must submit his closure
plan to the Regional Administrator no
later than 15 days after:
Check for presence of a closure
plan.
Document lack of a closure plan.
Upon closure, check facility com-
pliance file for closure plan sub-
mitted to RA and for approval of RA.
Document inadequacies or dis-
crepancies in compliance file.
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(1) termination of interim status
(except when a permit Is Issued to the
facility simultaneously with termination
of interim status; or
(2) Issuance of a judicial decree or
compliance order under Section 3008 of
RCRA to cease receiving wastes or close.
§265.113 Time Allowed for Closure.
(a) Within 90 days after receiving the Check to determine whether all wastes Document Inadequate execution of
final volume of hazardous wastes, or have been removed, or disposed of within proper closure activities.
90 days after approval of the closure plan, 90 days of receiving the final volume
if that 1s later, the owner or operator of wastes.
must treat, remove from the site, or
dispose of on-site all hazardous wastes
in accordance with the approved closure
plan. The Regional Administrator may
approve a longer period using the pro-
cedures under I265.112(d) if the owner
or operator demonstrates that:
(1){1) The activities required to
comply with this paragraph will, of
necessity, take him longer than 90 days
to complete; or
(11)(A) The facility has the capacity
to receive additional wastes;
(B) There Is a reasonable likelihood
that a person other than the owner or
operator will commence operation of
the site; and
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(C) Closure of the facility would be
Incompatible with continued operation
of the site; and
(2) He has taken and will continue to
take all steps to prevent threats to
human health and the environment.
(b) The owner or operator must complete
closure activities in accordance with the
approved closure plan and within 180 days
after receiving approval of th» closure
plan, If that is later. The Regional
Administrator nay approve a longer closure
period using the procedures under
§265.112(c) if the owner or operator
demonstrates that:
(l)(i) The closure activities will, of
necessity, take him longer than 180 days
to complete; or
(11)(A)The facility has the capacity to
receive additional waste;
(B)There is a reasonable likelihood that
a person other than the owner or operator
will recommence operation of the site;
(C) Closure of the facility would be
Incompatible with continue operation
of the site; and
Check to verify that all closure
activities are completed within
180 days after receiving the final
volume of waste.
Document inadequate execution of
closure activities
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(2) He has taken and will continue to
take all steps to prevent threats to
human health and the environment from
the unclosed but inactive facility.
§265.114 Disposal or Decontamination of
Equipment.
When closure is completed, all facility
equipment and structures must have been
properly disposed of, or decontaminated
by removing all hazardous waste and
residues.
§265.115 Certification of Closure.
When closure Is completed, the owner
or operator must submit to the Regional
Administrator certification both by the
owner or operator and by an independent
registered professional engineer that the
facility has been closed in accordance
with the specifications in the approved
closure plan.
§265.117 Post-Closure Care and Use of
Property; Period of Care.
(a) Post-closure care must continue for
30 years after the date of completing
closure and must consist of at least
the following:
Check for adequate decontamination
and disposal of equipment and
structures. Check for residual
wastes, lake samples.
Check facility compliance file for
certification of closure by RA and
registered professional engineer.
Document evidence of residual
hazardous wastes or improper
disposal. Photograph.
Document sample locations.
Document inadequacies or dis-
crepancies in compliance file.
Check to ensure post-closure care
is being continued.
Document inadequacies in post-
closure care.
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(1) Ground-water Monitoring and
reporting in accordance with the
requirements of Subpart F, and
(2) Maintenance of monitoring and
waste containment system as specified
in §§265.310, where applicable.
(b) The Regional Administrator may
require continuation of any of the
security requirements of §§265.14 for
30 years after the date closure has
been completed when:
(1) Wastes may remain exposed after
completion of closure; or
(2) Access by the public or domestic
livestock may pose a hazard to human
health.
In extending any of these requirements
the Regional Administrator will use the
procedures of §265.118(c).
(c) Post-closure use of property on or
in which hazardous wastes remain after
closure must never be allowed to disturb
the integrity of the final cover, liner(s),
or any other components of any contain-
ment system, or the function of the
facility's monitoring systems, unless
the owner or operator can demonstrate
to the Regional Administrator, either
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In the post-closure plan or by petition,
through the procedures In §265.118(c)
or (f) as appropriate, that the distur-
bance:
(1) Is necessary to the proposed use
of the property, and will not increase
the potential hazard to human health or
the environment; or
(2) Is necessary to reduce a threat to
human health or the environment.
(d) All post-closure care activities
must be performed in accordance with
the provisions of the approved post-
closure plan as specified in §265.118.
§265.118 Post-Closure Plan; Amendment of
Plan.
(a) By May 19, 1981, the owner or
operator of a disposal facility must
have a written post-closure plan. He
must keep a copy of this plan and all
revisions to the plan at the facility
until the post-closure period begins.
This plan must Identify the activities
which will be carried on after closure
and the frequency of those activities.
Check for presence of a post-
closure plan.
Document lack of post-closure
plan.
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(c) The owner or operator of a dis-
posal facility must submit his post-
closure plan to the Regional Administrator
at least 180 days before the date he
expects to begin closure. The Regional
Administrator will modify or approve the
plan within 90 days of receipt and after
providing the owner or operator and the
affected public (through a newspaper notice)
the opportunity to submit written comments.
§265.119 Notice to Local Land Authority.
• •.fi 90 days after closure is com-
pleted, the owner or operator of a dis-
posal facility must submit to the local
zoning authority or the authority with
jurisdiction over local land use and to
the Regional Administrator a survey plat
indicating the location and dimensions of
landfill cells or other disposal areas with
respect to permanently surveyed benchmarks.
This plat must be prepared and certified by
a professional land surveyor. The plat
filed with the authority or the authority
must contain a note, prominently displayed,
which states the owner's or operator's
obligation to restrict disturbance of the
site as specified In §265.117(c). In
addition, the owner or operator must
submit to the Regional Administrator and
to the local zoning authority or the
authority with jurisdiction over local
Check facility compliance file
for post-closure plan submitted
to RA and approved by RA.
Document lack of post-closure
plan or discrepancies in plan.
Check to ensure the Notice has been
submitted the local zoning authority
and survey plat contains the required
information:
location and dimensions of landfill
cells or other disposal areas
plat certification by professional
land survey
owner's or operator's obligation
to restrict disturbance of site
type, location and quantity of
hazardous waste.
Document non-compliance and in-
adequate in notice.
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land use a record of the type, location.
and quantity of hazardous wastes disposed
of within each cell or area of the
facility. For wastes disposed of before
these regulations were promulgated, the
owner or operator must identify the type,
location, and quantity of the wastes to
the best of his knowledge and in
accordance with any records he has
kept. Any changes in the type, location,
or quantity of hazardous waste disposed
of within each cell or area of the
facility that occur after the survey
plat and record of wastes have been
filed must be reported within 30
days to the local zoning authority
or the authority with jurisdiction
over local land use and to the
Regional Administrator.
§265.120 Notice in Deed to Property.
(a) The owner of the property on which
a disposal facility is located must record,
In accordance with State law, a notation
on the deed to the facility property—or
on some other instrument which is normally
examined during title search—that will in
perpetuity notify any potential purchaser
of the property that:
(1) the land has been used to manage
hazardous wastes;
Check for copy of deed to verify
that the notice of the site's use as
a hazardous waste facility has been
incorporated.
Document the absence of the nolir
Obtain copy of deed or notifying
instrument.
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(2) Us use is restricted under
S265.117(c); and
(3) The survey plat and record of the
type, location, and quantity of hazardous
waste disposed of within each cell area
of the facility required In §265.119 have
been filed with the local zoning authority
or the authority with jurisdiction over
local land use and with the Regional
Administrator of the Environmental
Protection Agency.
(b) If at any time the owner or
operator or any subsequent owner of the
land upon which a hazardous waste
facility was located removes the waste
and waste residues, the liner, if any.
and all contaminated underlying and
surrounding soil, he nay remove the
notation on the deed to the facility
property or other instrument normally
examined during title search.
Subpart I - Use and Management of Containers
§265.171 Condition of Containers.
If a container holding hazardous waste Inspect for leakage or corrosion of Note and describe non-compliance
Is not in good condition, or if it begins containers. Check dales on containers Document improper manifesting
to leak, the owner or operator must to determine container ane and inte- procedures. Photograph if
transfer the hazardous waste from this grily. Check manifest procedures if necessary.
container to a container that is in good waste is removed from site.
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condition, or manage the waste in some
other way that complies with the require-
ments of this Part.
§265.172 Compatibility of Waste with
Container.
The owner or operator must use a con-
tainer made of or lined with materials
which will not react with, and are
otherwise compatible with, the hazardous
waste to be stored, so that the ability
of the container to contain the waste is
not impaired.
§265.173 Management of Containers.
(a) A container holding hazardous waste
must always be closed during storage,
except when it Is necessary to add or
remove waste.
(b) A container holding hazardous
waste must not be opened, handled, or
stored in a manner which nay rupture
the container or cause it to leak.
5265.176 Special Requirements for
Ignitable or Reactive Waste.
Containers holding ignttable or reactive
waste must be located at least IS meters
(50 feet) from the facility's property
line.
Check condition and material of con-
tainer (bulging, heat generation, etc.)
Check records for verification
of materials used.
Document non-compliance.
Photograph.
Inspect storage site, look for open
containers. Check integrity of con-
conlainers. Inspect for leaks.
Document non-compliance.
Photograph.
Measure distance between waste and
facility property line.
Document non-compliance.
Photograph if necessary.
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§265.177 Special Requirements for
Incompatible Wastes.
(a) Incompatible wastes, or Incompatible
wastes and materials (see Appendix V for
examples), must not be placed in the same
container unless §265.17(b) is complied
with.
(b) Hazardous waste must not be placed
In an unwashed container that previously
held an Incompatible waste or material
(see Appendix V for examples), unless
§265.17(b) Is complied with.
(c) A storage container holding a
hazardous waste that Is incompatible
with any waste or other materials
stored nearby In other containers,
piles, open tanks, or surface impound-
ments must be separated from the other
materials or protected from them by
means of a dike, berm, wall, or other
device.
Subpart J - Tanks
§265.192 General Operating Requirements.
(a) Treatment or storage of hazardous
waste in tanks must comply with §265.17(b).
Check records to identify incom-
patible wastes. Determine whether
wastes in container are compatible.
Check procedures for handling
used containers.
Inspect for separating barriers
between incompatible hazardous
wastes.
Identify incompatible wastes.
Document non-compliance.
Document non-compliance.
Locate and document non-complian
Photograph if necessary.
Inspect containers and storage area
for ignition or reaction (e.g. open
flames, smoking, hot surfaces, sparks,
radiant heat).
Note locations of inadequate
containers. Photograph if
i f necessary.
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(b) Hazardous wastes or treatment
reagents must not be placed In a tank if
they could cause the tank or Its inner
liner to rupture, leak, corrode, or other-
wise fail before the end of its intended
life.
(c) Uncovered tanks must be operated to
ensure at least 60 centimeters (2 feet)
of freeboard, unless the tank is equipped
with a containment structure (e.g., dike
or trench), a drainage control system, or
a diversion structure (e.g., standby tank)
with a capacity that equals or exceeds the
volume of the top 60 centimeters (2 feet)
of the tank.
(d) Where hazardous waste is continuously
fed into a tank, the tank must be equipped
with a means to stop this inflow (e.g., a
waste feed cutoff system or by-pass system
to a stand-by tank).
S265.193 Waste Analysis and Trial Tests.
(a) In addition to the waste analysis
required by §265.13, whenever a tank is
to be used to:
(1) Chemically treat or store a
hazardous waste which is substantially
different from waste previously treated
or stored in that tank; or
Inspect containers for leakage, or
cracking, or corrosion.
Check specification numbers.
Measure freeboard i f necessary.
Document non-compliance.
Photograph.
Inspect for adequate waste feed
cutoff or by-pass system.
Describe non-compliance.
Inspect the facility operating
record for the results from each
waste analysis and trial test or
the documented information.
Note missing records and/or obtai
copies of inadequate records or
documentation.
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(2) Chemically treat hazardous waste
with a substantially different process
than any previously used In thdt tank;
the owner or operator must, before
treating or storing the different waste or
using the different process:
(i) Conduct waste analyses and trial
treatment or storage tests (e.g. , bench
scale or pilot plant scale tests); or
(ii) Obtain written, documented
information on similar storage or
treatment of similar waste under
similar operating conditions;
to show that this proposed treatment
or storage will meet all applicable
requirements of §265.192(a) and (b).
§265.194 Inspections.
(a) The owner or operator of a tank
must inspect, where present:
(1) Discharge control equipment (e.g.,
waste feed cut-off systems, by-pass
systems, and drainage systems), at least
once each operating day, to ensure that
it is in good working order;
(2) Data gathered from monitoring equip-
ment (e.g., pressure and temperature
guages), at least once each operating day,
to ensure that the tank is being operated
according to its design;
Check records and facility logs
for compliance with inspection
requirements.
Inspect condition of tank and
surrounding area for corrosion
or leakage.
Note discrepancies and missing
records. Obtain copies of
incomplete records. Photograph
if necessary. Document non-
compliance.
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(3) The level of waste In the tank, at
least once each operating day, to ensure
compliance with §265.192
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§265.198 Special Requirements for
Ignitable or Reactive Waste.
(a) Ignitable or reactive waste must not
be placed in a tank unless:
(1) The waste is treated, rendered, or
mixed before or immediately after place-
ment In the tank so that (1) the result-
ing waste, mixture, or dissolution
of material no longer meets the defini-
tion of Ignitable or reactive waste
under §§261.21 or 261.23 of this Chapter,
and (II) §265.17(b) Is complied with; or
(2) The waste Is stored or treated in
such a way that it is protected from any
material or conditions which may cause
the waste to ignite or react; or
(3) The -tank is used solely for
emergencies.
(b) The owner or operator of a facility
which treats or stores ignitable or
reactive waste in covered tanks must
comply with the National Fire Protection
Association's (NFPA's) buffer zone
requirements for tanks, contained in
Tables 2-1 through 2-6 of the "Flammable
and Combustible Code—1977."
Identify wastes through chemical
test records or other available
records. Check tank for heat
generation, volatile explosions,
fumes, etc. Check lab analyses
and reports.
Note location of wastes. Documei
evidence of non-compliance.
Sample wastes for flash-point testing.
Examine records. Note location of
wastes.
Verify emergency status.
Examine records to ascertain
adherence to required specifications.
Document non-compliance.
Document non-compliance.
Document non-compliance.
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§265.199 Special Requirements for
Incompatible Wastes.
(a) Incompatible wastes, or Incompatible
wastes and materials, (see Appendix V for
examples) must not be placed in the same
tank, unless §265.17(6) is complied with.
(b) Hazardous waste must not be placed
in an unwashed tank which previously
held an incompatible waste or material,
unless §265.17(b) is complied with.
Subpart X - Surface Impoundments
§265.222 General Operating Requirements.
A surface impoundment must maintain
enough freeboard to prevent any over-
topping of the dike by overfilling, wave
action, or a storm. There must be at
least 60 centimeters (2 feet) of free-
board.
§265.223 Containment System.
All earthen dikes must have a pro-
tective cover, such as grass, shale, or
rock, to minimize wind and water erosion
and to preserve their structural integrity.
§265.225 Waste Analysis and Trial Tests.
Check records for evidence of
incompatibility. Check for
evidence of explosion, chemical reac-
tion, heat generation, volatile gases,
etc. Inquire about operational pro-
cedures (decontamination and reuse of
tanks).
Document non-compliance.
Photograph. Note discrepancies.
Inspect for maintenance of 2 feet
of freeboard.
Document non-compliance.
Photograph.
Check integrity of cover on
earthen dikes.
Document non-compliance.
Photograph.
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(a) In addition to the waste analyses
required by §265.13, whenever a surface
impoundment Is to be used to:
(1) Chemically treat a hazardous
waste which Is substantially different
from waste previously treated in that
impoundment; or
(2) Chemically treat hazardous waste
with a. substantially different process
than any previously used In that impound-
ment; the owner or operator must, before
treating the different waste or using the
different process:
(1) Conduct waste analyses and trial
treatment tests (e.g., bench scale or pilot
plant scale tests); or
(11) Obtain written, documented informa-
tion on similar treatment of similar waste
under similar operating conditions to show
that this treatment will comply with
§265.17(b).
§265.226 Inspection.
(a) The owner or operator must Inspect:
(1) The freeboard level at least once
each operating day to ensure compliance.
with §265.222; and
Inspect the facility operating
record for the results from
each waste analysis and trial test
or the documented information
Obtain copies of inadequate repoi
or note missing reports. Note
discrepancies.
Check records showing compliance
with required inspections.
Obtain copies of inadequate
inspection reports and note
missing reports.
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(2) The surface Impoundment, Including
dikes and vegetation surrounding the
dike, at least once a week to detect any
leaks, deterioration, or failures in the
impoundment.
§265.228 Closure and Post-closure.
(a) At closure, the owner or operator
may elect to remove from the impoundment:
(1) Standing liquids;
(2) Waste and waste residues;
(3) The liner, if any; and
(4) Underlying and surrounding
contaminated soil.
(b) If the owner or operator removes
all the Impoundment materials in paragraph
(a) of this Section, or can demonstrate
under §261.3(c) and (d) of this Chapter
that none of the materials listed in para-
graph (a) of this Section remaining at any
state of removal are hazardous wastes, the
impoundment is not further subject to the
requirements of this Part.
(c) If the owner or operator does not
remove all the Impoundment materials in
paragraph (a) of this Section, or does
not make the demonstration in paragraph (b),
he must close the impoundment and provide
post-closure care as for a landfill under
Subpart G and §265.310. If necessary to
Check for adequate removal
through inspection of shipping
papers. Sample remaining
residual wastes or check for
adequate compliance with clo-
sure plan.
Note and describe non-compliance.
7/24/81
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support the final cover specified \r. the
approved closure plan, the owner or
operator must treat remaining liquids.
residues, and soils by removal of liquids,
drying, or other means.
§265.229 Special Requirements for
Ignitable or Reactive Waste.
(a) Ignitable or reactive waste must not
be placed In a surface impoundment, unless:
(1) The waste is treated, rendered, or
mixed before or immediately after place-
ment in the Impoundment so that (i) the
resulting waste, mixture, or dissolution
of material no longer meets the definition
of Ignitable or reactive waste under
§§261.21 or 261.23 of this Chapter, and
(II) §265.17(b) is complied with; or
(2) The surface Impoundment is used
solely for emergencies.
§265.230 Special Requirements for
Incompatible Wastes.
Incompatible wastes, or incompatible
wastes and materials, (see Appendix V
for examples) must not be placed in the
same surface impoundment, unless
§265.17(b) Is complied with.
Identify waste types through
chemical analysis records or any
testing records available.
Inspect surface impoundment for
chemical reactions, heat genera-
ation, volatile gases, etc.
Document evidence of non-
compliance. Sample waste for
flash point testing. Locate
sample on a diagram of the impoui
ment.
Inspect documents ensuring
compliance with required regulations.
Document non-compliance.
7/24/81
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Subpart L - Waste Piles
§265.251 Protection from Wind.
The owner or operator of a pile con-
taining hazardous waste which could be
subject to dispersal by wind Bust cover
or otherwise manage the pile so that wind
dispersal is controlled.
§265.252 Waste Analysis.
In addition to the waste analyses
required by §265.13, the owner or
operator Bust analyze a representative
sample of waste from each Incoming
movement before adding the waste to
any existing pile, unless (1) the only
wastes the facility receives which are
amenable to piling are compatible with
each other, or (2) the waste received is
compatible with the waste in the pile to
which il Is to be added. The analysis
conducted must be capable of differentiating
between the types of hazardous waste the
owner or operator places in piles, so that
mixing of incompatible waste does not
Inadvertently occur. The analysis must
Include a visual comparison of color and
texture.
Inspect site for wind dispersal
control.
Document non-compliance.
Photograph if necessary.
Inspect the facility operating
record for the results from each
waste analysis and trial Lest or
the documented information.
Note inadequacies or discrepancie
Sample if necessary. Document no
compliance.
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§265.253 Containment.
If leachate or run-off from a pile is a
hazardous waste, then either:
(a) The pile must be placed on an imper-
meable base that Is compatible with the
waste under the conditions of treatment
or storage; run-on must be diverted away
from the pile, and any leachate and
run-off from the pile must be collected
and managed as a hazardous waste; or
(b)(l) The pile must be protected from
precipitation and run-on by some other
means; and
(2) No liquids or wastes containing
free liquids may be placed in the pile.
§265.256 Special Requirements for
Ignitable or Reactive Waste.
(a) Ignitable or reactive wastes must
not be placed in a pile, unless:
(1) Addition of the waste to an
existing pile (1) results in the waste
or mixture no longer meeting the
definition of ignitable or reactive
waste under §§261.21 or 261.23 of this
Chapter, and (ii) complies with §265.17(b);
or
Inspect records of chemical
wastes and base material.
Inspect for run-on diversion and
run-off collection.
Note inadequate records. Sample
i f necessary. Document non-
compliance. Photograph.
Identify wastes through chemical
test records or other available
records. Check for explosions,
heat generation, volatile gases, etc.
Sample wastes for flash-point
testing. Note location of
wastes on facility diagram.
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(2) The waste 1s managed In such a way
that it is protected from any material or
conditions which may cause it to ignite
or react.
§265.257 Special Requirements for
Incompatible Wastes.
(a) Incompatible wastes, or incom-
patible wastes and materials, (see
Appendix V for examples) must not be
placed in the same pile, unless
§265.17(b) is complied with.
(b) A pile of hazardous waste that is
incompatible with any waste or other
material stored nearby In other con-
tainers, piles, open tanks, or surface
impoundments must be separated from the
other materials, or protected from them
by means of a dike, berm, wall, or
other device.
(c) Hazardous waste must not be piled on
the same area where incompatible wastes
or materials were previously piled, unless
that area has been decontaminated
sufficiently to ensure compliance with
§265.17(5).
Check records to identify types of
wastes. Check for evidence of chemical
reactions, heat generation, volatile
gases, etc.
Inspect for barrier compliance.
Identify wastes types.
Document non-compliance.
Document non-compliance.
Check waste placement records.
Obtain copies of records
indicating improper placement.
7/24/61
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Subpart M - Land Treatment
§265.272 General Operating Requirements.
(a) Hazardous waste must not be placed
In or on a land treatment facility
unless the waste can be made less hazardous
or non-hazardous by biological degradation
or chemical reactions occuring in or on the
soil.
(b) Run-on must be diverted away from
the active portions of a land treatment
facility.
(c) Run-off from active portions of a
land treatment facility must be collected.
(d) The date for compliance with para-
graphs (b) and (c) of this Section is 12
months after the effective date of this
Part. (November 19. 1981)
§265.273 Waste Analysis.
In addition to the waste analyses
required by §265.13, before placing a
hazardous waste in or on a land treat-
ment facility, the owner or operator
must:
(a) Determine the concentrations in the
waste of any substances which exceed the
the maximum concentrations contained in
Check approval document.
Note missing records.
Locate active portions.
Inspect for run-on diversion.
Locate active portions.
Inspect for run-off collection.
Check record dates.
Note location of discrepancies.
Photograph if necessary.
Document non-compliance.
Document non-compliance.
Inspect the facility operating
record Tor the results from each
waste analysis and trial test or
the documented information.
Note incomplete records.
Obtain copies of erroneous
records or note missing records.
7/2^/81
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Table I of §261.24 of this Chapter that
cause a waste to exhibit the EP toxicity
characteristic;
(b) For any waste listed in Part 261,
Subpart 0, of this Chapter, determine the
concentrations of any substances which
caused the waste to be listed as a hazardous
waste; and
(c) If food chain crops are grown,
determine the concentrations in the waste
of each of the following constituents:
arsenic, cadmium, lead, and mercury,
unless the owner or operator has written.
documented data that show that the con-
stituent Is not present.
§265.276 Food Chain Crops.
(a) An owner or operator of a hazardous
waste land treatment facility on which
food chain crops are being grown, or have
been grown and will be grown in the future.
must notify the Regional Administrator
within 60 days after the effective date of
this Part (November 19, 1981).
(b)(l) Food chain crops must not he
grown on the treated area of a hazardous
waste land treatment facility unless the
owner or operator can demonstrate, based
on field testing, that any arsenic, lead,
mercury, or other constituents identified
under §265.273(b):
Check to ensure proper notification
has been given.
Note discrepancies.
Chpck testing records and
and analyses.
Note inadequate records.
7/24/81
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(1) Will not be transferred to the food
portion of the crop by plant uptake or
direct contact, and will not otherwise be
ingested by food chain animals (e.g., by
grazing); or
(11) Will not occur 1n greater con-
centrations in the crops grown on the
land treatment facility than in the same
crops grown on untreated soils under
similar conditions In the same region.
(2) The Information necessary to make
the demonstration required by paragraph
(b)(l) of this Section must be kept at
the facility and must, at a minimum:
(1) Be based on tests for the specific
waste and application rates being used
at the facility; and
(11) Include descriptions of crop and
soil characteristics, sample selection
criteria, sample size determination,
analytical methods, and statistical pro-
cedures.
(c) Food chain crops must not be grown
on a land treatment facility receiving
waste that contains cadmfum unless all
requirements of paragraph (c)(l)(1)
through (1ii) of this section or all re-
quirements of paragraph (c)(2)(i) through
(iv) of this Section are met.
7/24/81
Inspect information at the facility
in regard to:
- Specific waste tests;
- Application rates;
- Crop descriptions;
- Soil characteristics;
- Sample determination;
- Sample selection criteria;
- Analytical methods; and
- Statistical procedures.
Document inadequacies.
Obtain copies.
Check pH levels with a pll meter.
Sample soils for cadmium content.
Insure compliance with levels
required in §265.27G(c)(l). (See
Attachment J)
VII-57
Document non-compliance.
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(2)(i) The only food chain crop pro-
duced Is aninal feed.
(H) The pH of the waste and soiI
mixture 1s 6.5 or greater at the time
of waste application or at the time
the crop is planted, whichever occurs
later, and this pH level is maintained
whenever food chain crops are grown.
(iii) There is a facility operating
plan which demonstrates how the aninal
feed will be distributed to preclude
ingest ion by humans. The facility
operating plan describes the Measures to
be taken to safeguard against possible
health hazards from cadmium entering the
food chain, which may result from
alternative land uses.
(iv) Future property owners are notified
by a stipulation in the land record or
property deed which states that the
property has received waste at high
cadmium application rates and that
food chain crops should not be grown,
due to a possible health hazard.
§265.278 Unsaturated Zone (Zone of
Aeration) Monitoring.
(a) The owner or operator must have in
writing, and must implement, an unsatur-
ated zone aionitorlng plan which is
designed to:
Note discrepancies or
inadequate reports.
Check operating plan for demonstra-
tion of adequate procedures and
measures.
Obtain copies.
Check records for notification.
Note inadequate reports.
copies.
Obtain
Inspect the operating record of
the facility for adequate
unsaturateil zoni» monitoring plan.
Document inadequacies. Obtain
copies of incomplete records.
7/24/81
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(1) Detect the vertical migration of
hazardous waste and hazardous waste con-
stituents under the active portion of the
land treatment facility; and
(2) Provide information on the back-
ground concentrations of the hazardous
waste and hazardous waste constituents
In similar but untreated soils nearby.
This background monitoring must be con-
ducted before or in conjunction with the
monitoring required under paragraph (a)(l)
of this Section.
(b) The unsaturated zone monitoring plan
must include, at a minimum:
(1) Soil monitoring using soil cores; and
(2) Soil-pore water monitoring using
devices such as lysimeters.
(c) To comply with paragraph (a)(l) of
this Section, the owner or operator must
demonstrate in his unsaturated zone moni-
toring plan that:
(1) The depth at which soil and soil-pore
water samples are to be taken is below the
depth to which the waste is incorporated
into the soil;
(2) The number of soil and soil-pore water
samples to be taken is based on the
variability of:
Check all sampling and analysis
reports.
Obtain copies of incomplete
records. Note missing records.
Check records for inclusion of all
required information.
Note discrepancies.
7/24/81
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(i) The hazardous waste constituents (as
identified in §265.273(a) and (b)) in the
waste and in the soil; and
(ii) The soil type(s); and
(3) The frequency and timing of soil and
soil-pore water sampling is based on the
frequency, time, and rate of waste applica-
tion, proximity to ground water, and soil
permeability.
(d) The owner or operator must keep at
the facility his unsaturated zone moni-
toring plan and the rationale used in
developing this plan.
(e) The owner or operator must analyze
the soil and soil-pore water samples for
the hazardous waste constituents that
were found in the waste during the waste
analysis under §265.273 (a) and (b).
§265.279 Recordkeep i ng.
The owner or operator of a land treatment
facility must keep records of the
application dates, application rates.
quantities, and location of each hazardous
waste placed in the facility, in the oper-
ating record required In §265.73.
Check for presence of monitoring
plan and an explanation of the plan.
Check records for sample analysis
results.
Document non-compliance.
Document non-camp1i ance.
Inspect records for inclusion of
all required information.
Obtain copies of inadequate
records.
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§265.280 Closure and Post-Closure.
(d) In addition to the requirements of
§265.117, during the post-closure care
period, the owner or operator of a land
treatment facility roust:
(1) Maintain any unsaturated zone
system, and collect and analyze samples
from this system in a manner and
frequency specified in the post-closure
plan;
(2) Restrict access to the facility as
appropriate for its post-closure use; and
(3) Assure that growth of food chain
crops complies with §265.276.
§265.282 Special Requirements for
Incompatible Wastes.
Incompatible wastes, or incompatible
wastes and materials (see Appendix V
for examples) must not be placed in the
same land treatment area, unless
§265.17(b) is complied with.
§265.281 Special Requirements for
Ignitable or Reactive Waste.
Ignltable or reactive wastes must not
be land treated, unless the waste is
immediately Incorporated into the soil
7/24/81
Check for approved closure plan in
permit and compliance with plan.
Check monitoring records and
analysis reports.
Check facility access restrictions.
Note discrepancies in record-
keeping or monitoring procedures
Sample, if appropriate.
Check records to identify
incompatible wastes. Inspect
land treatment areas for chemical
reactions, heat generation,
volatile gases, elc.
Identify wastes through chemical
analysis records or any testing
records available. Check for
VII-61
Identify incompatible wastes.
Locate and sample,.if
appropriate.
Document evidence of non-
compliance. Sample wastes
for flash-point testing.
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DOCUMENTATION
so that (1) the resulting waste mixture,
or dissolution of material no longer
meets the definition of ignltable or
reactive waste under §§261.21 or 261.23
of this Chapter, and (2) §265.17(b) is
complied with.
Subpart N - Landfills
§265.302 General Operating Requirements.
(a) Run-on must be diverted away from
the active portions of a landfill.
(b) Run-off from active portions of a
landfill must be collected.
(d) The owner or operator of a landfill
containing hazardous waste which is
subject to dispersal by wind must cover
or otherwise manage the landfill so that
wind dispersal of the hazardous waste is
controlled.
§265.309 Surveying and Recordkeeping.
The owner or operator of a landfill
•ust maintain the following items in the
operating record required in §265.73:
(a) On a nap, the exact location and
dimensions, including depth, of each cetl
with respect to permanently surveyed
benchmarks; and
explosions, heat generation,
volatile gases, etc.
Locate on a facility diagram.
Locate active portions of landfill.
Inspect for run-on diversion and
run-off collection.
Inspect site for blowing debris
and chock «:ovcr.i«j«>.
Inspect records for inclusion of
map and complete information on
cell dimensions, location and
contents.
Note location of discrepancies.
Photograph if necessary.
Document non-compliance.
Photograph.
Obtain copies of incomplete
or erroneous records. Note
missing records.
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(b) The contents of each cell and the
approximate location of each hazardous
waste type within each cell.
§265.310 Closure and Post-closure.
(a) The owner or operator must place
a final cover over the landfill, and the
closure plan under §265.112 must specify
the function and design of the cover. In
the ps-:-t-closure plan under §265.118, the
owner or operator must include the post-
closure care requirements of paragraph (d)
of this Section.
§265.312 Special Requirements for Ignitable
or Reactive Waste.
Ignitable or reactive waste must not be
placed In a landfill, unless the waste is
treated, rendered, or mixed before or
Immediately after placement in the landfill
so that (1) the resulting waste mixture
or dissolution of material no longer meets
the definition of Ignitable or reactive
waste under §§261.21 or 261.23 of this
Chapter, and (2) §265.17(b) is complied
with.
§265.313 Special Requirements for
Incompatible Wastes.
Incompatible wastes, or incompatible
wastes and materials, (see Appendix V
7/24/81
Inspect landfill cover and
post-closure plan. Specify
function and design of cover.
Note inadequacies.
Inspect records and approval
documents showimj wastes properly
rendered. Check landfill area lor
evidence of explosions, heat genera-
tion volatile gases, etc.
Document non-compliance.
Sample if necessary.
Inspect operatintj records for cell
contents. Check for evidence of
VI1-63
Document non-compliance.
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for examples) must not be placed in the
same landfill cell unless §265.17(b) is
complied with.
§265.314 Special Requirements for
Liquid Waste.
(a) Bulk or non-containerized liquid
waste or waste containing free liquids
must not be placed in a landfill, unless:
(1) The landfill has a liner which is
chemically and physically resistant to
the added liquid, and has a functioning
leachate collection and removal system
with a capacity sufficient to remove
all leachate produced; or
(2) Before disposal, the liquid waste or
waste containing free liquids is treated
or stabilized, chemically or physically
(e.g., by mixing with an absorbant solid),
so that free liquids are no longer present.
(b) A container holding liquid waste
or waste containing free liquids must not
be placed in a landfill, unless:
(1) The container is designed to hold
liquids or free liquids for a use other
than storage, such as a battery or
capacitor; or
chemical reactons, heat generation,
volatile gases, etc.
Check approval documents for liner
requirements. Check for removal
capacity of leachate collection and
removal system. Check manifests
contents.
Sample waste. Document
non-compliance. Photograph.
Check manifests for contents of
containers or drums disposed of
in landfill.
Document non-compliance.
Obtain copies of manifests.
Photograph.
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(2) The container Is very small, such
as an ampule.
§265.315 Special Requirements for
Containers.
(a) An empty container must be crushed
flat, shredded, or similarly reduced in
volume before it is buried beneath the
surface of a landfill.
§265.310 Closure and Post-Closure.
(b) In addition to the requirements of
§265.117, during the post-closure care
period, the owner or operator of a
hazardous waste landfill must:
(1) Maintain the function and integrity
of the final cover as specified in the
approved closure plan;
(2) Maintain and monitor the leachate
collection, removal, and treatment
system (if there is one present in the
landfill) to prevent excess accumulation
of leachate in the system;
[Comment: If the collected leachate is a
hazardous waste under Part 261 of this
Chapter, it must be managed as a
hazardous waste in accordance with all
Check landfill for proper treatment
of drums and containers.
Document non-compliance.
Photograph if necessary.
Check operation plan for procedures
used to maintain, monitor and comply
with the post-closure plan.
Check logs for compliance.
Obtain copes of documents. Not«
discrepancies. Document non-
compliance.
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applicable requirements of Parts 262,
263, and 265 of this Chapter. If the
collected leachate Is discharged through
a point source to waters of the United
States, it Is subject to the requirements
of Section 402 of the Clean Water Act as
amended.]
(3) Maintain and monitor the gas
collection and control system (if there is
one present in the landfill) to control
the vertical and horizonal escape of gases;
(4) Protect and maintain surveyed
benchmarks; and
(5) Restrict access to the landfill as
appropriate for its post-closure use.
Subpart 0 - Incinerators
§265.341 Waste Analysis.
In addition to the waste analyses
required by §265.13, the owner or
operator must sufficiently analyze any
waste which he has not previously
burned in his Incinerator to enable him
to establish steady state (normal)
operating conditions (Including waste
and auxiliary fuel feed and air flow) and
to determine the type of pollutants
which might be emitted. At a minimum,
the analysis must determine:
Check maintenance of monitoring
systems, beanchmarks, and access
restrictions.
Document inadequate maintenance.
Photograph.
Check records of analysis of
waste, including:
- Heating valve;
- Haloqpn content;
- Sulfur content;
- Concentration of lead; and
- Concentration of mercury.
Obtain copies of inadequate or
or incomplete records'. Document
non-compliance.
7/24/81
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(a) Heating value of the waste;
(b) Halogen content and sulfur content
In the waste; and
(c) Concentrations In the waste of lead
and mercury, unless the owner or operator
has written, documented data that show
that the element is not present.
§265.345 General Operating Requirements.
During start-up and shut-down of an
incinerator the owner or operator must
not feed hazardous waste unless the
incinerator is at steady state (normal)
conditions of operation, including
steady state operation temperature and
air flow.
§265.347 Monitoring and Inspections.
(a) The owner or operator must conduct,
as a minimum, the following monitoring
and inspections when incinerating
hazardous wastes:
(1) Existing Instruments which relate
to combustion and emission control
must be monitored at least every 15
minutes. Appropriate corrections to
maintain steady state combustion
conditions must be made immediately
either automatically or by the operator.
Check operating procedures,
temperature and air flow.
i.e.
Note operator's failure to
meet specifications.
Check monitoring records. Note
recording methods. Observe on-
site operation. Inquire about
on-site inspection procedures.
Note descrepancies in records.
Obtain copies. Document
evidence of inadequate site
monitoring.
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Instruments which relate to combustion
and emission control would normally
include those measuring waste feed,
auxiliary fuel feed, air flow, inciner-
ator temperature, scrubber flow, scrubber
pH, and relevant level controls.
(2) The stack plume (emissions) must
be observed visually at least hourly for
normal appearance (color and opacity).
The operator must Immediately make any
indicated operating corrections necessary
to return visible emissions to their
normal appearance.
(3) The complete Incinerator and
associated equipment (pumps, valves,
conveyors, pipes, etc.) must be Inspected
at least daily for leaks, spills, and
fugitive emissions, and all emergency
shutdown controls and system alarms must
be checked to assure proper operation.
§265.351 Closure.
At closure, the owner or operator must
remove all hazardous waste and hazardous
waste residues (including but not limited
to ash, scrubber waters, and scrubber
sludges) from the incinerator.
Observe on-site operation.
Document non-compliance.
Photograph.
Check Inspection records. Observe
normal inspection procedures carried
out by fac iIi ty personneI.
Document non-compliance.
Check for adequate removal
through inspection of shipping
papers and other documentation of
hazardous waste transport. Sample
residuals from incinerators.
Note and document non-compliance.
Obtain copies, if necessary.
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Subpart P - Thermal Treatment
S265.373 General Operating Requirements.
Before adding hazardous waste, the
owner or operator must bring his thermal
treatment process to steady state
(normal) conditions of operation-
Including steady state operating
temperature—using auxiliary fuel or
other means, unless the process is a
non-continuous (batch) thermal treat-
ment process which requires a complete
thermal cycle to treat a discrete quantity
of hazardous waste.
§265.375 Waste Analysis.
In addition to the waste analyses
required by §265.13. the owner or
operator must sufficiently analyze any
waste which he has not previously
treated in his thermal process to enable
him to establish steady state (normal) or
other appropriate (for a non-continuous
process) operating conditions (including
waste and auxiliary fuel feed) and to
determine the type of pollutants which
night be emitted. At a minimum, the
analysis must determine:
(a) Heating value of the waste;
Inquire about operating procedures,
i.e., temperature of steady state
operation.
Note operations not meeting
specifications.
Check records of analyses of
wastes for inclusion of:
- Healing value;
- Halogen content;
- Sulfur content;
- Concentration of lead; and
- Concentration of mercury.
Obtain copies of inadequate
records. Document non-complianc
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(b) Halogen content and sulfur content
in the waste; and
(c) Concentrations 1n the waste of lead
and mercury, unless the owner or operator
has written, documented data that show
that the element is not present.
§265.377 Monitoring and Inspections.
(a) The owner or operator must conduct,
as a minimum, the following monitoring
and inspections when thermally treating
hazardous waste:
Check monitoring records.
Inspect monitoring methods
and devices. Observe on-site
operation.
Note descrepancies. Obtain copies
of inadequate records.
(1) Existing Instruments which relate
to temperature and emission control (if
an emission control device is present)
must be monitored at least every 15 minutes.
Appropriate corrections to maintain steady
state or other appropriate thermal treatment
conditions roust be made immediately either
automatically or by the operator. Instru-
ments which relate to temperature and emission
control would normally Include those measuring
waste feed, auxiliary fuel feed, treatment
process temperature, and relevant process
flow and level controls.
(2) The stack plume (emissions), where
present, must be observed visually at
least hourly for normal appearance (color
and opacity). The operator must immediately
Observe on-site operation.
Document non-compliance.
Photograph.
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make any Indicated operating corrections
necessary to return any visible emissions
to their normal appearance.
(3) The complete thermal treatment
process and associated equipment (pumps,
valves, conveyors, pipes, etc.) must be
checked to assure proper operation.
§265.381 Closure.
At closure, the owner or operator must
remove all hazardous waste and hazardous
waste residues (Including, but not
limited to, ash) from the thermal
treatment process or equipment.
S265.382 Open Burning; Waste Explosives.
Open burning of hazardous waste Is
prohibited except for the open burning
and detonation of waste explosives.
Waste explosives Include waste which
has the potential to detonate and bulk
military propellents which cannot safely
be disposed of through other modes of
treatment. Detonation 1s an explosion in
which chemical transformation passes
through the material faster than the speed
of sound (0.33 kilometers/second at sea
level). Owners or operators choosing to
open burn or detonate waste explosives
Check records for operator's
compliance. Inquire about/observe
Inspection procedures.
Check for adequate removal through
inspection of shipping papers ami other
documentaton of hazardous waste
transport. Sample residuals from
thermal treatment process or
equipment.
Check documents insuring wastes are
classified as explosives. Inspect
open burning or detonation procedures
to ensure compliance with required
regulations.
Document non-compliance.
Note and document non-compliance.
Document non-compliance.
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must do so in accordance with the following
table and in a manner that does not threaten
human health or the environment.
Pounds of waste
explosives or
propellants
Minimum distance from
open burning or deton-
ation to the property
of others.
0 to 100 204 meters (670 feet)
101 to 1,000 380 meters (1.250 ft.)
1,001 to 10,000 530 meters (1,730 ft.)
10,001 to 30,000 690 meters (2,260 ft.)
(1.3
(2,5
Subpart Q - Chemical. Physical and Biological Treatment
§265.401 General Operating Requirements.
(a) Chemical, physical, or biological
treatment of hazardous waste must comply
with §265.17(b).
(b) Hazardous wastes or treatment
reagents must not be placed in the
treatment process or equipment if they
could cause the treatment process or
equipment to rupture, leak, corrode, or
otherwise fail before the end of its
intended life.
Check records covering injiitable,
inactive or incompatible wastes.
Inspect for evidence of fire,
explosions, fumes, heat and
pressure. Check integrity of
waste containers, (bulging seams.
corrosion, leakage, etc.)
Obtain copies of inadequate
records. Note missing records.
Note discrepancies. Photograph.
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(c) Where hazardous waste Is continu-
ously fed Into a treatment process or
equipment, the process or equipment must
be equipped with a means to stop this
Inflow (e.g., a waste feed cut-off system
or by-pass system to a standby containment
device).
§265.402 Waste Analysis and Trial Tests.
(a) In addition to the waste analysis
required by §265.13, whenever:
(1) A hazardous waste which Is sub-
stantially different from waste pre-
viously treated in a treatment process
or equipment at the facility Is to be
treated in that process or equipment; or
(2) A substantially different process
than any previously used at the facility
Is to be used to chemically treat
hzardous waste; the owner or operator
must, before using the different
process or equipment:
(1) Conduct waste analyses and trial
treatment tests (e.g., bench scale or
pilot plant scale tests); or
(11) Obtain written, documented informa-
tion on similar treatment of similar waste
under similar operating conditions;
Inspect for maintenance of
a waste feed cut-off or by-pass
system.
Document non-compliance.
Review records of waste analysis
performed. Check all operation
and procedures logs noting new
entries. Check all analysis
reports for compliance with
§265.401.
Document non-compliance.
Obtain copies of records.
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to show that this proposed treatment
will meet all applicable requirements
of §265.401 (a) and (b).
§265.403 Inspections.
(a) The owner or operator of a treat-
ment facility must inspect, where present:
(1) Discharge control and safety equip-
ment (e.g., waste feed cut-off systems,
by-pass systems, drainage systems, and
pressure relief systems) at least once
each operating day, to ensure that it is
in good working order;
(2) Data gathered from monitoring
equipment (e.g., pressure and tempera-
ture guages), at least once each
operating day. to ensure that the treat-
ment process or equipment Is being operated
according to its design;
(3) The construction materials of the
treatment process or equipment, at least
weekly, to detect corrosion or leaking
of fixtures or seams; and
(4) The construction materials of, and
the area immediately surrounding,
discharge confinement structures (e.g..
dikes), at least weekly, to detect erosion
or obvious signs of leakage (e.g., wet
spots or dead vegetation).
Inquire about inspection procedures
for monitoring, control and safety
equipment. Observe on-site opera-
ation.
Note descrepancies. Obtain
copies of inadequate records.
Check monitoring records for
adequate data.
Document non-compliance.
Photograph.
Observe on-site operation.
Check for corrosion or leaking
of fixtures or seams in
construction materials.
Inspect surrounding areas for signs
of leakage or erosion.
Document non-compliance.
Photograph.
Photograph.
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S265.405 Special Requirements for
Ignitable or Reactive Waste.
(a) Ignltable or reactive waste must not
be placed In a treatment process or
equipment unless:
(1) The waste Is treated, rendered, or
mixed before or Immediately after place-
ment In the treatment process or equipment
so t»"» (i) the resulting waste, mixture,
or , jtion of material no longer meets
the definition of Ignltable or reactive
waste under §§261.21 or 261.23 of this
Chapter, and (11) §265.17(b).is complied
with; or
(2) the waste Is treated In such
a way that il is protected from any
material or conditions which may cause the
waste to ignite or react.
§265.406 Special Requirements for
Incompatible Wastes.
(a) Incompatible wastes, or incompatible
wastes and materials (see Appendix V for
examples), must not be placed in the same
treatment process or equipment, unless
§265.17(b) is complied with.
(b) Hazardous waste must not be placed
in unwashed treatment equipment which
Identify wastes through chemical
test records or other available
records. Check lab analysis reports.
Check for heat generation, explosions,
fumes, etc. Sample wastes for flash-
point testing.
Note location of wastes.
Document non-compliance.
Check records for evidence of
incompatibility. Check for
evidence of explosion, chemical
reactions, heat generation,
volatile gases, etc.
Document non-compliance.
Photograph.
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previously heTd an Incompatible waste or
material, unless §265.17(b) is complied
with.
§265.404 Closure.
At closure, all hazardous waste and
hazardous waste residues must be
removed from treatment processes or
equipment, discharge control equipment,
and discharge confinement structures.
Subpart R - Underground Injection
Subparts B. C, D, E, F
(General Facility Standards; Prepared-
ness and Prevention; Contingency Plan
and Emergency Procedures; Manifest
Recordkeeping and Reporting; and
Groundwater Monitoring).
Examine facility records.
Inspect all equipment and
discharge structures. Take
samples of residual waste.
Consult appropriate suhparts.
Document non-compliance.
Photograph.
Document accordingly.
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ATTACHMENT A
§262.20 General Requirements.
(b) A generator must designate on the manifest one facility which is
permitted to handle the waste described on the manifest.
(c) A generator may also designate on the manifest one alternate facil-
ity which is permitted to handle his waste in the event an emergency pre-
vents delivery of the waste to the primary designated facility.
(d) If the transporter is unable to deliver the hazardous waste to the
designated facility or the alternate facility, the generator must either
designate another facility or instruct the transporter to return the waste.
§252.21 Required Information.
(a) The manifest must contain all of the following information:
(1) A manifest document number;
(2) The generator's name, mailing address, telephone number, and EPA
identification numoer;
(.'" The name and EPA identification number of each transporter;
(~ .he name, address and EPA identification number of the designated
facility and an alternate facility, if any;.
(5) The description of the waste(s) (e.g., proper shipping name, etc.)
required by regulations of the U.S. Department of Transportation in 49 CFR
172.101, 172.202, and 172.203;
(6) The total quantity of each hazardous waste by units of weight or
volume, and the type and nnmber of containers as loaded into or onto the
transport vehicle.
(b) The following certification must appear on the manifest: "This is
to certify that the above named materials are properly classified, des-
cribed, packaged, marked, and labeled and are in proper condition for trans-
portation according to the applicable regulations of the Department of
Transportation and the EPA."
§262.23 Use of the Manifest.
(a) The generator must:
(1) Sign the manifest certification by hand;
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(2) Obtain the handwritten signature of the inital transporter and date
of acceptance on the manifest; and
(3) Retain one copy, in accordance with §262.40(a).
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ATTACHMENT B
§265.13 General Waste Analysis.
(a) (3) The analysis must be repeated as necessary to ensure that it is
accurate and up to date. At a minimum, the analysis must be repeated:
(i) When the owner or operator is notified, or has reason to believe,
that the hazardous waste received at the facility does not match the waste
designated on the accompanying manifest or shipping paper.
(4) The owner or operator of an off-site facility must inspect and, if
necessary, analyze each hazardous waste movement received at the facility to
determine whether it matches the identity of the waste specified on the
accompanying manifest or shipping paper.
(b) At a minimum, the plan must specify:
(1) The parameters for which each hazardous waste will be analyzed and
the rationale for the selection of these parameters (i.e., how analysis for
these parameters will provide sufficient information on the waste's proper-
ties to comply with paragraph (a) of this Section);
(2) The test methods which will be used to test for these parameters;
(3) The sampling method which will be used to obtain a representative
sample of the waste to be analyzed. A representative sample may be obtained
using either:
(i) One of the sampling methods described in Appendix I of Part 261 of
this Chapter; or
(ii) An equivalent sampling method. (Comment: See §260.20(c) of this
Chapter for related discussion.)
(4) The frequency with which the initial analysis of the waste will be
reviewed or repeated to ensure that the analysis is accurate and up to date;
(5) For off-site facilities, the waste analyses that hazardous waste
generators have agreed to supply; and
(6) Where applicable, the methods which will be used to meet the addi-
tional waste analysis requirements for specific waste management methods as
specified In S§ 265.193, 265.225, 265.273, 265.345, 265.375, and 265.402.
(c) For off-site facilities, the waste analysis plan required 1n para-
graph (b) of this Section must also specify the procedures which will be
used to inspect and, if necessary, analyze each movement of hazardous waste
received at the facility to ensure that it matches the Identify of the waste
designated on the accompanying manifest or shipping paper. At a minimum,
the plan must describe:
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(1) The procedures which win be used to determine the identity of each
movement of waste managed at the facility; and
(2) The sampling method which will be used to obtain a representative
sample of the waste to be identified, if the identification method includes
s.impling.
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ATTACHMENT C
S265.14 Security.
(a) The owner or operator must prevent the unknowing entry, and mini-
mize the possibility for the unauthorized entry, of persons or livestock
onto the active portion of his facility, unless:
(1) Physical contact with the waste, structures, or equipment with the
active portion of the facility will not injure unknowing or unauthorized
persons or livestock which may enter the active portion of a facility, and
(2) Disturbance of the waste or equipment, by the unknowing or un-
authorized entry of persons or livestock onto the active portion of a facil-
ity, will not cause a violation of the requirements of this Part.
(b) Unless exempt under paragraphs (a)(l) and (a)(2) of this Section, a
facility must have:
(1) A 24-hour surveillance system (e.g., television monitoring or
surveillance by guards or facility personnel) which continuously monitors
and controls entry onto the active portion of the facility; or
(2)(i) An artificial or natural barrier (e.g., a fence in good repair
or a fence combined with a cliff) which completely surrounds the active
portion of the facility; and
(ii) A means to control entry, at all times, through the gates or other
entrances to the active portion of the facility (e.g., an attendant, tele-
vision monitors, locked entrance, or controlled roadway access to the facil-
ity).
[Comment: The requirements of paragraph (b) of this Section are satisfied if
the facility or plant within which the active portion is located itself has
a surveillance system, or a barrier and a means to control entry, which
complies with the requirements of paragraph (b)(l) or (b)(2) of this
Section.]
(c) Unless exempt under paragraphs (a)(l) and (a)(2) of this Section, a
sign with the legend, "Danger—Unauthorized Personnel Keep Out," must be
posted at each entrance to the active portion of a facility, and at other
locations, in sufficient numbers to be seen from any approach to this active
portion. The legend must be written 1n English and in any other language
predominant in the area surrounding the facility (e.g., facilities in coun-
ties bordering the Canadian provice of Quebec oust post signs In French;
facilities in counties bordering Mexico Bust post signs 1n Spanish), and
must be legible from a distance of at least 25 feet. Existing signs with a
legend other than "Danger—Unauthorized Personnel Keep Out" may be used if
the legend on the sign Indicates that only authorized personnel are allowed
to enter the active portion, and that entry onto the active portion can be
dangerous.
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ATTACHMENT D 9938-2
§265.15 General Inspection Requirements
(3) The schedule must identify the types of problems (e.g., malfunc-
tions or deterioration) which are to be looked for during the inspection
(e.g., inoperative sump pump, leaking fitting, eroding dike, etc.).
(4) The frequency of inspection may vary for the Hems on the schedule.
However, it should be based on the rate of possible deterioration of the
equipment and the probability of an environmental or human health incident
if the deterioration or malfunction or any operator error goes undetected
between inspections. Areas subject to spills, such as loading and unloading
areas, must be inspected daily when in use. At a minimum, the inspection
schedule must include the items and frequencies called for in §§265.174,
265.194, 265.226, 265.347, 265.377, and 265.403.
(c) The owner or operator must remedy any deterioration or malfunction
of equipment or structures which the inspection reveals on a schedule which
ensures that the problem does not lead to an environmental or human health
hazard. Where a hazard is imminent or has already occurred, remedial action
must be taken immediately.
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ATTACHMENT E
§265.16 Personnel Training.
(a)(1) Facility personnel must successfully complete a program of
classroom instruction or on-the-job training that teaches them to perform
their duties in a way that ensures the facility's compliance with the re-
quirements of this Part. The owner or operator must ensure that this pro-
gram includes all the elements described in the document required under
paragraph (d)(3) of this Section.
(2) This program must be directed by a person trained in hazardous
waste management procedures, and must include instruction which teaches
facility personnel hazardous waste management procedures (including con-
tingency plan implementation) relevant to the positions in which they are
employed.
(3) At a minimum, the training program must be designed to ensure that
facility personnel are able to respond effectively to emergencies by famili-
arizing them with emergency procedures, emergency equipment, and emergency
systems, including where applicable:
(i) Procedures for using, inspecting, repairing, and replacing facility
emergency and monitoring equipment;
(ii) Key parameters for automatic waste feed cut-off systems;
(iii) Communications or alarm systems;
(iv) Response to fires or explosions;
(v) Response to groundwater contamination incidents; and
(vi) Shutdown of operations.
(b) Facility personnel must successfully complete the program required
in paragraph (a) of this Section within six months after the effective date
of their employment or assignment to a facility, or to a new position at a
facility, whichever is later. Employees hired after the effective date of
these regulations must not work In unsupervised positions until they have
completed the training requirements of paragraph (a) of this Section.
(c) Facility personnel must take part in an annual review of the ini-
tial training required in paragraph (a) of this Section.
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ATTACHMENT F 9938 2
§265.52 Content of Contingency Plan.
(a) The contingency plan must describe the actions facility personnel
must take to comply with §§265.51 and 265.56 in response to fires, explo-
sions, or any unplanned sudoen or non-sudden release of hazardous waste or
hazardous waste constituents to air, soil, or surface water at the facility.
(b) If the owner or operator has already prepared a Spill Prevention
Control, and Countermeasures (SPCC) Plan in accordance with Part 122 of this
Chapter, or some other emergency or contingency plan, he need only amend
that plan to incorporate hazardous waste management provisions that are
sufficient to comply with the requirements of this Part.
(c) The plan must describe arrangements agreed to by local police
departments, fire departments, hospitals, contractors, and State and local
wnergency services, pursuant to §265.37.
(d) The plan must list names, addresses, and phone numbers (office and
home) of all persons qualifies to act as emergency coordinator (see
5265.55), and this list must be kept up to date. Where more than one person
•is listed, one must be named as primary emergency coordinator and others
must be listed in the order in which they will assume responsibility as
.alternates.
(e) The plan must include a list of all emergency equipment at the
facility (such as fire extinguishing systems, spill control equipment, com-
munications and alarm systems (internal and external), and decontamination
equipment), where this equipment is required. This list must be kept up to
date. In addition, the plan must include the location and a physical de-
scription of each item on the list and a brief outline of its capabilities.
(f) The plan must include an evacuation plan for facility personnel
where there is a possibility that evacuation could be necessary. This plan
must describe signal(s) to be used to begin evacuation, evacuation routes,
and alternative evacuation routes (in cases where the primary routes could
be blocked by releases of hazardous waste or fires).
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ATTACHMENT G
§265.73 Operating Record.
(b) The following information must be recorded, as_it becomes avail-
able, and maintained in the operating record until closure of the facility:
(1) A description and the quantity of each hazardous waste received,
and the method(s) and date(s) of its treatment, storage, or disposal at the
facility as required by Appendix I;
(2) The location of each hazardous waste within the facility and the
quantity at each location. For disposal facilities, the location and quan-
tity of each hazardous waste must be recorded on a map or diagram of each
cell or disposal area. For all facilities, this information must include
cross-references to specific manifest document numbers, if the waste was
accompanied by a manifest;
[Comment: See §§265.119, 265.279, and 265.309 for related requirements.]
(3) Records and results of waste analyses and trial tests performed as
specified in §§265.13, 265.193, 265.225, 265.252, 265.273, 265.345, 265.375,
and 265.402;
(4) Summary reports and details of all incidents that require imple-
menting the contingency plan as specified in §265.56(j);
(5) Records and results of inspections as required by §265.15(d) (ex-
cept these data need be kept only three years);
(6) Monitoring, testing, or analytical data where required by §§265.90,
265.94, 265.276, 265.278, 265.280(d)(l), 265.347, and 265.377; and
(7) All closure cost estimates under §265.142 and, for disposal facil-
ities, all post-closure cost estimates under §265.144.
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ATTACHMENT H "°38- 2
§265.92 Sampling and Analysis
(b) (1) Parameters characterizing the suitability of the groundwater as
a drinking water supply, as specified in Appendix III.
(2) Parameters establishing groundwater quality:
(i) Chloride;
(ii) Iron;
(iii) Manganese;
(iv) Phenols;
(v) Sod i urn;
(vi) Sulfate
[Comment: These pa-ameters are to be used as a basis for comparison in the
event a grounowater quality assessment is required under 5265.93(d}.]
(3) Parameter used as indicators of groundwater contamination:
(ii) Specific Conductance;
(iii) Total Organic Carbon;
(iv) Total Organic Halogen.
(c)(l) For all monitoring wells, the owner or operator must establish
initial background concentrations or values of all parameters specified in
paragraph (b) of this section. He must do this quarterly for one year.
(2) For each of the indicator parameters specified in paragraph (b){3)
of this Section, at least four replicate measurements must be obtained for
each sample and the initial background arithmetic mean and variance must be
determined by pooling the replicate measurements for the respective para-
meter concentrations or values in samples obtained from upgradient wells
during the first year.
(d) After the first year, all monitoring wells Bust be sampled and the
samples analyzed with the following frequencies:
(1) Samples collected to establish groundwater quality must be obtained
and analyzed with the parameters specified in paragraph (b)(2) of this
Section at least annually.
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(2) Samples collected to indicate groundwater contamination must be
obtained and analyzed for the parameters specified in paragraph (b)(3) of
this Section at least semi-annually.
(e) Elevation of the ground**: surface at each monitoring well must
be determined each time a sample is lained.
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OQ7Q
ATTACHMENT I * ' J °'
§265.93 Preparation, Evaluation, and Response (GrounoVater Monitoring).
(a)(l) Whether hazardous waste or hazardous waste constituents have
entered the grounowater;
(2) The rate and extent of migration of hazardous waste or hazardous
waste constituents in the groundwater; and
(3) The concentrations of hazardous waste or hazardous waste con-
stituents in the groundwater.
(b) For each indicator parameter specified in §265.(b)(3), the owner
or operator must calculate the arithmetic mean and variance, based on at
least four replicate measurements on each sample, for each well monitored in
accordance with §265.92(d)(2) , and compare these results with its initial
background arithmetic mean. The comparison must consider individually each
of the wells in the monitoring system, and just use the Student's t-test at
the 0.01 level of significance (see Appendix IV) to determine statistically
significant increases (and decreases, in the case of pH) over initial back-
ground.
(c)(l) If the comparisons for the up gradient wells made under para-
graph (b) of this Section show a significant increase (or pH decrease), the
owner or operator must submit this information in accordance with §265. (a)
(2) If the comparisons for downgradient wells made under paragraph (b)
of this Section show a significant increase (or pH decrease), the owner or
operator must then immediately obtain additional groundwater samples from
those downgradient wells where a significant difference was detected, split
the samples in two, and obtain analyses of all additional samples to deter-
mine whether the significant difference was a result of laboratory error.
(d)(l) If the analyses performed under paragraph (c)(2) of this Sec-
tion confirm the significant increase (or pH decrease), the owner Bust
provide written notice to the Regional Administrator—within seven days of
the date of such confirmation— that the facility may be affecting ground-
water quality.
(2) Within 15 days after the notification under paragraph (d)(l) of
this Section, the owner or operator must develop and submit to the Regional
Administrator a specific plan, based on the outline required under paragraph
(a) of this Section and certified by a qualified geologist or geotechnical
engineer, for a groundwater quality assessment program at the facility.
(3) The plan to be submitted under §265.90(d)(l) or paragraph (d)(2)
of this Section must specify:
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ATTACHMENT I, Continued
(i) The number, location, and depth of wells;
(ii) Sampling and analytical methods for those hazardous waste con-
stituents in the facility;
(iii) Evaluation procedures, including any use of previously gathered
groundwater quality information; and
(iv) A schedule of implementation.
(4) The owner or operator must implement the groundwater quality
assessment plan which satisfies the requirements of paragraph (d)(3) of this
Section, and, at a minimum, determine:
(i) The rate and extent of migration of the hazardous waste or haz-
ardous waste constituents in the groundwater; and
(ii) The concentrations of the hazardous waste or hazardous waste
constituents in the groundwater.
(5) The owner or operator must make his first determination under
paragraph (d)(4) of this Section as soon as technically feasible, and,
within 15 days after that determination, submit to the Regional Admini-
strator a written report containing an assessment of the groundwater quali-
ty.
(6) If the owner or operator determines, based on the results of the
first determination under paragraph (d)(4) of this Section, that no hazard-
ous waste or hazardous waste constituents from the facility have entered the
groundwater, then he may reinstate the indicator evaluation program de-
scribed in §265.92 and paragraph (b) of this Section. If the owner or
operator reinstate the indicator evaluation program , he must so notify the
Regional Administrator in the report submitted under paragraph (d)(5) of
this Section.
(7) If the owner or operator determines, based on the first deter-
mi nation under paragraph (d)(4) of this Section, that hazardous waste or
hazardous waste constituents from the facility have entered the groundwater,
then he:
(i) Must continue to make the determinations required under paragraph
(d)(4) of this Section on a quarterly basis until final closure of the
facility, 1f the groundwater quality assessment plan was Implemented prior
to final closure of the facility; or
(11) Hay cease to make the determinations required under paragraph
(d)(4) of this Section, 1f the groundwater quality assessment plan was
Implemented during the post-closure care period.
(e) Notwithstanding any other provision of this Subpart, any ground-
water quality assessment to satisfy the requirements of §265.93(d)(4) which
7/24/81 VII-89 RCRA INSPECTION MANUAL
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9938.2
is initiated prior to final closure of the facility must be completed and
reported in accordance with S265.93(d)(5).
(f) Unless the groundwater is monitored to satisfy the requirements of
§i!65.93(d)(4), at least annually the owner or operator must evaluate the
data on groundwater surface elevations obtained under §265.92(e) to deter-
mine whether the requirements under §265.91(a) for locating the monitoring
wells continues to be satisfied. If the evaluation shows that §265.91(a) is
no longer satisfied, the owner or operator must immediately modify the
number, location, or depth of the monitoring wells to bring the groundwater
monitoring system into compliance with this requirement.
7/24/81 VII-90 RCRA INSPECTION MANUAL
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ATTACHMENT J
§265.276 Food Chain Crops
(c)(l)(i) The pH of the waste and soil mixture is 6.5 or greater at the
time of each waste application, except for waste containing cadmium at
concentrations of 2 mg/kg [dry weight] or less;
(ii) The annual application of cadmium from waste does not exceed 0.5
kilograms per hectare (kg/ha) on land used for production of tobacco, leafy
vegetables, or root crops grown for human consumption. For other food chain
crops, the annual cadmium application rate does not exceeed:
Time Period Annual Cd Application
Rate (kg/ha)
Present to June 30, 1984 2.0
July 1, 1984 to Dec. 31, 1984 1.25
Beginning Jan. 1, 1967 0.5
(iii) The cumulative application of cadmium from waste does not exceed
the levels in either paragraph (c)(l)(iii)(A) of this Section or paragraph
(c)(l)(iii)(B) of this Section.
(A)
Maximum cumulative
application (kg/ha)
Soil cation exchange
capacity (meq/lOOg)
Less than 5
5-15
Greater than 15
Background
soil pH less
than 6.5
5
5
5
Background
soil pH greater
than 6.5
5
10
20
(B) For soils with a background of pH of less than 6.5, the cumulative
cadmium application rate does not exceed the levels below: Provided, that
the pH of the waste and soil mixture 1s adjusted to and maintained at 6.5 or
greater whenever food chain crops are grown.
7/24/81 VII-91 RCRA INSPECTION MANUAL
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ATTACHMENT J Continued Q Q 1 Q ~,
1 ' *-> >- . L,
Soil cation excnange capacity Maximum cumulative
(meq/lOOg) application (kg/ha)
Less than 5 5
5-15 10
Greater than 15 20
7/24/81 VI1-92 RCRA INSPECTION MANUAL
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Figure 10
BCRA SITE INSPECTION CHECKLIST
A. Sue Name
B. Street (or other identifier)
C. City
D. State
E. Zip Code F. County Name
G. Site Operator Information
1. Name
3. Street
4. City
2. Telephone Number
5. State 6. Zip Code
H. Site Description
I. Type of Ownership
1. Federal 2. State 3. County 4. Municipal 5. Private
7.
1. Generator 2. Transporter 3. Treatment 4. Storage 5. Disposal
INSPECTION INFORMATION
A. Principal Inspector Information
1. Name
3. Organization
2. Title
4. Telephone No. (area code & No.)
B.Inspection Participants
7/24/81
VII-93
RCRA INSPECTION MANUAL
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Figure 11 9938.2.
GENERATORS CHECKLIST
Section A - EPft Identification No.
1. Does Generator have EPA I.D. No.? Yes No
a. If yes, EPA I.D. No.
Section 8 - Manifest
1. Does generator ship waste off-site? Yes No
a. If no, do not fill out Sections 6 and D
b. If yes, identify primary off-site facility(s)
Use narrative explanations sheet.
2. Does generator use Manifest? Yes No
a. If no, is generator a small quantity generator: Yes No
1. If yes, does generator indicate this when
sending waste to a T/S/D facility Yes No
b. If yes, does manifest include the following
information?
1. Manifest Document No. Yes No
2. Generators Name, Mailing Address,
-Telephone No. Yes No
3. Generator EPA I.D. No. Yes No
4. Transporteds) Name and EPA I.D. No. Yes No
5. a. Facility Name, Address and EPA I.D. No. Yes No
b. Alternate Facility Name, Address and
EPA I.D. No. Yes No
c. Instructions to return to generator if
undeliverable? Yes NO
6. Waste Information required by DOT - Shipping
name, quantity, (weight, or vol.) containers
(type and number.) Yes No
7. Emergency Information (optional)
(special handling instructions, phone no.) Yes No
7/24/81 VI1-94 RCRA INSPECTION MANUAL
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8. Is the following certification on each
manifest form? Yes "No
This is to certify that the above named
materials are properly classified, described,
packaged, marked and labeled and are in
proper condition for transportation accord-
ing to the applicable regulations of the
Department of Transportation and the EPA.
9. Does Generator retain copies of Manifests? Yes No
If yes, complete a through e.
a. (1) Did generator sign and date all manifests? Yes No
(2) Who signed for generator?
Name Title
(1) Did generator obtain handwritten signature and
date of acceptance from initial transporter? Yes No
(2) Who signed and dated for transporter
Name Title
c, Does generator retain one copy of manifest signed
by generator and transporter? Yes No
d. Do returned copies of manifest include facility
owner/operator signature and date of acceptance? Yes No
e. Does generator retain copies for 3 years? Yes No
Section C - Hazardous Waste Determination
1. Does generator generate solid waste(s) listed in
Subpart D (List of Hazardous Waste)? Yes No
a. If yes, list waste and quantities
(include EPA Hazardous Waste No.)
2. Does generator generator solid waste(s) listed in
Subpart C that exhibit hazardous characteristics?
(corrosivity, ignitabillty, reactivity, EP toxidty) Yes No
If yes, 11st wastes and quantities
(Include EPA Hazardous Waste No.) "
b. Does generator determine characteristics by testing
or by applying knowledge of processes?
1. If determined by testing, did generator use test
methods in Part 261, Subpart C (or Equivalent)? Yes No
7/24/81 VI1-95 RCRA INSPECTION MANUAL
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9938.2
a. If equivalent test methods used, attach
copy of equivalent methods used.
.'3. Are there any other solid wastes generator by generators? Yes No
a. If yes, did generator test all wastes to determine
non-hazardous characteristics? Yes No
1. If no, list wastes and quantities deemed non-
hazardous or processes from which non-hazardous
waste was produced? (Use additional sheet if
necessary.)
Section D - Pre-Transport Requirements
1. Does Generator package waste in accordance with 49 CFR
173, 178, and 179? (DOT requirements) Yes No
2. a. Are containers to be shipped leaking or corroding? Yes No
b. Use sheet to describe containers and condition. Yes No
c. Is there evidence of heat generation from
incompatible wastes in the containers? Yes No
3. Does the genertor use DOT labeling reouirements in
accordance with 49 CFR 172? Yes No
4. Does the generator mark each package in accordance
with 49 CFR 172? Yes No
5. Is each container of 110 gallons or less marked with
the following label? Yes No
Label saying: HAZARDOUS WASTE - Federal
Law Prohibits Improper Disposal. If found,
contact the nearest policy or public safety
authority or the U.S. Environmental Pro-
tection Agency.
Generator/s Name and Address
Manifest Document Number
6. Does generator have placards to offer to transporters? Yes No
7/24/81 VI1-96 RCRA INSPECTION MANUAL
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7. Accumulation Time
a. Are containers used to temporarily store waste
before transport? Yes No
1. If yes, is each container clearly dated?
Also, fill out rest of No. 7 (Accum. Time) Yes No
b. 1. Does generator inspect containers for
leakage or corrosion? (265.174 - Inspections) Yes No
2. If yes, with what frequency?
c. Does generator locate containers holding ignitable
or reactive waste at least 15 meters (50 feet)
from the facility's property line? Yes Nc
(265.176 • Special Requirements for Ignitable
or Reactive Wastes)
NOTE: If tanks used, fill out checklist for tanks.
d. Are the containers labeled and marked in accordance
with Section D 3, 4, & 5 of this form? Yes No
NOTE: If generator accumulates waste on-site fill out
checklist for General Facilities, Subparts C and D
e. Does generator comply with requirements for personnel
training? (attach checklist for 265.16 - Personnel
Training). Yes No
8. Describe storage area. Use photos and narrative explanation sheet.
Section E - Recordkeeping and Records
1. Does generator keep the following reports for 3 years?
a. Manifests and signed copies from designated
facilities? Yes No
b. Annual reports Yes No
c. Exception Reports Yes No
d. Test results YesNo
2. Where are the records kept (at facility or elsewhere)?,
3. Who is in charge of keeping the records?
Name Title
7/24/81 VI1-97 RCRA INSPECTION MANUAL
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9933.2
Section F - Special Conditions
1. Has generator received from or transported to a
foreign source any hazardous waste? Yes_ No
a. If yes, has he filed a notice with the
Regional Administrator? Yes No
b. Is this waste manifested and signed by
Foreign consignee? Yes No
c. If generator transported wastes out of the
country has he received confirmation of
delivered shipment? Yes No
7/24/81 VII-98 RCRA INSPECTION MANUAL
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Figure 12
RCRA COMPLIANCE INSPECTION REPORT
FACILITIES CHECKLIST
Section A - General Facility Standards
1. Does facility have EPA Identification No.? Yes No
A. If yes, EPA I.D. No.
If no, explain
2. Has facility received hazardous waste from
a foreign source? Yes No
A. If yes, has he filed a notice with the
Regional Administrator? Yes No
Waste Analysis
3. Does facility maintain a copy of the waste analysis
plan at tne facility? Yes No
A. If yes, does it include
(1) Parameters for which each waste will
be analyzed? Yes No
(2) Test methods used to test for these
parameters? Yes No
(3) Sampling method used to obtain sample? Yes No
(4) Frequency with which the initial analyses
will be reviewed or repeated? Yes No
(5) (for off-site facilities) Waste analyses
that generators have agreed to supply? Yes No
(6) (for off-site facilities) Procedures which
are used to Inspect and analyze each
movement of hazardous waste Including:
a. Procedures to be used to determine the
Identity of each movement of waste? Yes No
b. Sampling method to be used to obtain
representative sample of the waste to
be identified? Yes No
7/24/81 VII-99 RCRA INSPECTION MANUAL
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9938.2
4. Does the facility provide adequate security through
A. 24-hour surveillance system? e.g. television
monitoring or guards) Yes No
OR
B. (1). Artificial or natural barrier around facility
(e.g. fence or fence and cliff)? Yes No
Describe
AND
(2) Means to control entry through entrances
(e.g. attendant, television monitors, locked
entrance, controlled roadway access)/ Yes No
Describe
General Inspection Requirements
5. Does the owner/operator maintain a written schedule
at the facility for inspecting:
a. Monitoring equipment?
b. Safety and emergency equipment?
c. Security devices?
d. Operating and structural equipment?
e. Types of problems of equipment?
1. malfunction
2. operator error
3. discharges
6. Does the owner/operator maintain an inspection log?
A. If yes, does it include:
(1) Date and time of Inspection?
(2) Name of Inspector:
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
(3) Notation of observations?
(4) Date and nature of repairs or remedial action? Yes No
7/24/81 VII-100 RCRA INSPECTION MANUAL
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B. Are there any malfunctions or other deficiencies
not corrected? (Use narrative explanation sheet). Yes ^Nc
Personnel Training
7. Does the owner/operator maintain Personnel
Training Records at the facility? Yes No
How long are they kept?
A. If yes, do they include:
(1) Job title and written job description of
each position? Yes No
(2) Description of type and amount of training? Yes No
(3) Records of training given to facility
personnel? Yes No
Requirements for Ignitable. Reactive or Incompatible Waste
8. Does facility handle ignitable or reactive wastes? Yes No
A. If yes, is waste separated and confined from
sources of ignition or reaction, (open flames,
smoking, cutting and welding, hot surfaces,
frictional heat) sparks (static, electrical
or mechanical), spontaneous ignition (e.g.
from heat producing chemical reactions) and
radiant heat? Yes No
1. If yes, use narrative explanations sheet to
describe separation and confinement procedures.
2. If no, use narrative explanation sheet to
describe sources of Ignition or reaction.
B. Are smoking and open flame confined to specifically
designated locations? Yes No
C. Are "No Smoking" signs posted in hazardous areas? Yes No
T. Check containers
A. Are containers leaking or corroding? Yes No
8. Is there evidence of heat generation from
incompatible wastes? Yes No
7/24/81 VII-101 RCRA INSPECTION MANUAL
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9938.2
Section B - Preparedness and Prevention
1. Is there evidence of fire, explosion or contamination
of the environment? Yes No
If yes, use narrative explanations sheet to explain.
T.Is the facility equipped with:
A. Internal communication or alarm system? Yes No
(1) Is it easily accessible in case of emergency? Yes No
B. Telephone or two-way radio to call emergency
response personnel? Yes No
C. Portable fire extinguishers, fire control
equipment spill control equipment and
decontair.ination equipment? Yes No
(1) Is this equipment tested to assure its
proper operation? Yes No
D. Water of adequate volume for hoses, sprinklers
or water spray system? Yes No
(1) Describe source of water
3. Is there sufficient aisle space to allow unobstructed
movement of personnel and equipment? Yes No
7!Has the owner/operator made arrangements with the
local authorities to familiarize them with charac-
teristics of the facility? (Layout of facility,
properties of hazardous waste handled and associated
hazards, places where facility personnel would
normally be working, entrances to roads inside
facility, possible evacuation routes.) Yes No
5^In the case that more than one police and fire
department might respond, is there a designated
primary authority? Yes No
If yes, list primary authority
b. Does the owner/operator nave phone numbers of
and agreements with State emergency response
teams, emergency response contractors and
equipment suppliers? Yes No
Are they readily available to all personnel? Yes No
T.Has the owner/operator arranged to familiarize
local hospitals with the properties of hazardous
waste handled and types of injuries that could
result from fires, explosions, or releases at
the facility? Yes No
7/24/81 VI1-102 RCRA INSPECTION MANUAL
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8. If State or local authorities decline to enter,
is this entered in the operating record? Yes No
Section C - Contingency Plan and Emergency Procedures
1. Is a contingency plan maintained at the facility: Yes No
A. If yes, is it a revised SPCC Plan? Yes No
2TIs there an emergency coordinator on site at all times?YesNo"
Section D - Manifest Syterc. Recordkeeping and Reporting
1. Does facility receive waste from off-site? Yes No
A. If yes, does the owner/operator retain copies of
all manifests? Yes No
(1) Are the manifests signed and dated and
returned to the generator? Yes No
(2) Is a signed copy given to the transporter? Yes No
T.Does the facility receive any waste from a rail or
water (bulk shipment) transporter? Yes No
A. If yes, is it accompanied by a shipping paper? Yes No
(1) Does the owner/operator sign and date the
shipping paper and return a copy to the
generator? Yes No
(2) Is a signed copy given to the transporter? Yes No
3. Has the owner/operator received any shipments of"
waste which were Inconsistent with the manifest?
(manifest discrepancies) Yes No
A. If yes, has he attempted to reconcile the dis-
crepancy with the generator and transporter? Yes No
(1) If no, has Regional Administrator been
notified? Yes No
4lDoes the owner/operator keep a written operating
record at the facility? Yes No
7/24/81 VI1-103 RCRA INSPECTION MANUAL
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S938.2
A. If yes, does it include:
(1) Description and quantity of each hazardous
waste received? Yes No
(2) Location and Quantity of each hazardous waste
at each location? Yes No
(3) Records and results of waste analyses? Yes No
(4) Report of incidents involving implementing
of the contingency plan? Yes No
(5) Records and results of required inspections? Yes No
(6) Monitoring, testing or analytical data? Yes No
(7) Closure cost estimates and for disposal
facilities post-closure cost estimates? Yes No
Has the facility received any waste (that does not
come under the small generator exclusion) not
accompanied by a manifest? Yes No
A. If yes, has he submitted an unmanifested waste
report to the Regional Administrator? Yes No
7/24/81 VI1-104 RCRA INSPECTION MANUAL
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Figure 13
LANDFILLS CHECKLIST
1. Is run-on diverted froir, the landfill?
(Effective November 19, 1981) __Yes _No
2. Is run-off from the landfill collected?
(Effective November 19, 1981) _Yes _Wo
a. Is this waste analyzed to determine
if it is a hazardous waste? Yes No
(1) If it is a hazardous waste, how is
it managed? (Use narrative explana-
tions sheet)
(2) Is the collected run-off discharged
through a point source to surface
waters? Yes No
(a) If yes, list NPDES Permit Number
3. Is the landfill managed so that wind dispersal
is controlled? (Note blowing debris) Yes _No
4. Is the following information maintained in the
operating record? Yes No
5. Are reactive or ignitable wastes placed in the
landfill? - _Yes __No
a. If yes, is it treated, rendered or mixed
before or immediately after placement in
the landfill so it is no longer reactive
or ignitable? _Yes __No
b. Describe treatment, etc, or attach a copy
of treatment
6. Are incompatible wastes placed in the same landfill? _Yes _N°
7. Are bulk or non-containerized liquid wastes or wastes
containing free liquids placed in the landfill?
(Effective November 19, 1981) _Yes No
7/24/81 VI1-105 RCRA INSPECTION MANUAL
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9938.2
a. If yes, does the landfill have
(1) A chemically and physically resistant liner? Yes No
(2) Functioning leachate collection and removal
system Yes No
or
b. 1. Is the liquid waste treated chemically or
physically so that free liquids are no
longer present? (Effective November 19, 1981) Yes No
8. Are containers holding liquid wastes placed in the
landfill? _Yes _No
a. If yes, is the container designed to hold
liquids for a use other than storage?
(e.g. battery, capacitor)
(Effective November 19, 1981) Yes __No
9. Are empty containers placed in the landfill? Yes No
a. If yes, are they reduced in volume (e.g.
shredded, crushed)? (Effective November 19, 1981) __Yes __No
10. Is there evidence of site instability? (e.g. erosion,
settling)? (Use narrative explanations sheet) _Jfes __No
11. Is there evidence of ponding of water on-site?
(Use narrative explanation sheet) Yes No
12. Is there any indication of Improper or inadequate
drainage? (Use narrative explanations sheet) Yes No
13. Does the facility maintain closure and post-closure
plans? Yes No
7/24/81 VI1-106 RCRA INSPECTION MANUAL
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FIGURE 14
WASTE PILES CHECKLIST
NOTE: Waste piles may also be managed as a landfill.
1. Is the pile containing hazardous waste protected
from wind? Yes No
2. Is a representative sample of waste from each incoming
shipment analyzed before the waste is added to the pile
to determine the compatibility of the wastes? Yes No
3. Does the analysis include a visual comparison of
color and texture? Yes No
4. Is the leachate or run-off from the pile considered
a hazardos waste? (Effective November 19, 1981) _Yes __N°
a. If yes, is the pile managed with the following?
(1) An impermeable base compatible with the waste? Yes No
(2) Run-on diversion? Yes No
(3) Leachate and run-off collection? Yes No
or
b. (1) Is the pile protected from precipitation
and run-on by some other means? Yes No
5. Are ignitable or reactive wastes placed in the pile? Yes No
a. If yes, does the addition of the waste result in
the waste or mixture no longer meeting the defini-
tion? (Use narrative explanation sheet to describe
procedure) Yes No
or
b. Is the waste protected from sources of ignition
or reaction? ___Yes __No
(1) If yes, use narrative explanations sheet
to describe separation and confinement
procedures.
(2) If no, use narrative explanations sheet to
describe sources of ignition or reaction.
6. Is the pile separated from other sources of reaction by
by a dike, bern or wall? Yes No
7. Is there evidence of fire, explosion, gaseous emissions,
leaching or other discharge? (Use narrative explanation
sheet) _Yes _No
7/24/81 VII-107 RCRA INSPECTION MANUAL
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FIGURE 15
SURFACE IMPOUNDMENTS CHECKLIST
1. Are there any surface Impoundments which are not being
used which the facility does not plan to use in the —
future? __Yes _J
-------
12. Are ignitable or reactive wastes placed in the
impoundment?
a. If no, do not complete b and c.
b. If yes, are they treated, rendered or mixed
before or immediately after placement in the
impoundment so it no longer meets the defini-
tion of igm'table or reactive? _Yes _^_No
or
c. Is the impoundment used solely for emergencies? Yes No
13. Are incompatible wastes placed in the impoundment? Yes __Nc
7/24/81 VII-109 RCRA INSPECTION MANUAL
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FIGURE 16 9938.2
INCINERATORS CHECKLIST
1. Is the incinerator operating at steady state condition
(temperature and air flow) before adding hazardous waste? Yes No
2. Is a waste analysis documented on the operating record
that includes:
a. Heating value Yes No
b. Halogen content Yes No
c. Sulfur content _Yes _N°
d. Concentration of lead Yes No
e. Concentration of mercury Yes No
(Note: d and e not required if facility has written
documented data that show the elements are not present.
3. Does the owner/operator monitor the following when inciner-
ating hazardous waste?
a. At least every 15 minutes, existing instruments which
relate to combustion ana emission control including:
(!) Waste feed __Yes No
(2) Auxiliary fuel feed _Yes ~~No
(3) Air flow __Yes ~No
(4) Incinerator temperature Yes No
(5) Scrubber flow Yes No
(6) Scrubber pH Yes No
(7) Relevant level controls Yes __No
b. Stack plume (emissions) at least hourly for:
(1) Color (normal) Yes No
(2) Opacity __Yes __No
c. Incinerator and associated equipment at least
daily including:
(1) Pumps, valves, conveyors, pipes for leaks,
spills, and fugitive emissions (Use narra-
tive explanations sheet) «Jte* _No
(2) Emergency shutdown controls _Jte* No
(3) Systems alarms _Jfes ^No
4. Is a closure plan maintained at the facility? Yes No
7/24/81 VII-110 RCRA INSPECTION MANUAL
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FIGURE 17
TANKS CHECKLIST
1. Are there any tanks which are not being used which
the facility no longer plans to use? __Yes No
a. If yes, has all hazardous waste and hazardous
waste residue been removed from these tanks,
discharge control equipment and discharge
confinement structures? Yes No
2. Are tanks presently used to treat or store waste? Yes No
a. If no, do not complete rest of form.
b. If yes, check tanks.
Is there evidence that incompatible wsates have
been placed in the tank? Is there evidence of
any ruptures, leaks or corrosion? (Use narra-
tive explanations sheet) Yes No
3. Are there any uncovered tanks? Yes No
a. If no, do not comolete 3b-3e
b. If yes, do they have 2 feet (60 cm) freeboard? Yes No
or
c. A containment structure? (e.g. dike or trench) Yes No
or
d. A drainage control system? Yes No
or
e. A diversion structure? (e.g. standby tank) _Yes _N°
(NOTE: The structure in c, d or e must
have a capacity that equals or exeeds the
volume of the top 2 feet (60 cm) of the
tank.
4. Are any of the tanks continuous feed? Yes No
a. If yes, 1s it equipped with a means to stop
•inflow (e.g. waste feed cutoff or by-pass to
a stand-by tank)? __Yes _No
7/24/81 VII-111 RCRA INSPECTION MANUAL
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9938.2
Waste Analysis
5. Is the tank used to store waste exclusively? Yes No
a. If no, what are the different wastes stored in
the tank? Use narrative explanations sheet)
b. Are waste analyses and trial treatment or storage
tests done on these different wastes? Yes No
(1) If no, does the owner/operator have written,
documented information on similar storage or
treatment of similar wastes? Yes No
c. Are there records available of these waste
analyses in the operating record? Yes No
Inspections
6. Does the owner/operator inspect the following at least
daily?
a. Discharge control equipment (e.g. waste feed
cut-off, by pass and/or drainage systems)? Yes No
b. Monitoring equipment (e.g. pressure and temper-
ature gases)? __Yes __No
c. Level of waste in each uncovered tank? _Yes "o
7. Does the owner/operator inspect the following at
least weekly?
a. Construction materials of tanks for corrosion or
leaks? _Yes _No
b. Construction materials of and area surrounding
discharge confinement structures for erosion or
signs of leakage? Yes No
8. Is a written schedule of these inspections kept at
the facility? __Yes _No
9. Does the facility maintain a record of the closure
plan on site? Yes No
10. Are ignitable or reactive wastes placed in tanks? _Yes _No
a. If yes, are they treated, rendered or mixed
before or immediately after placement in the
tank so it no longer meets the definition of
ignitable or reactive? Yes No
7/24/81 VII-112 RCRA INSPECTION MANUAL
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or
b. Is the waste protected from sources of ignition
or reaction? Yes No
(1) If yes, use narrative explanations sheet to
describe separation and confinement procedures.
(2) If no, use narrative explanations sheet to
describe sources of ignition or reaction
or
c. Is the tank used soley for emergencies? Yes No
11. Are incompatible wastes placed in the same tank? Yes No
12. If a waste is to be praced in a tank that previously
held an incompatible waste, was that tank washed? Yes No
a. If yes, describe washing procedures (Use narrative
explanations sheet)
Describe how it is possible for incompatible waste
to be placed in the same tank. (Use narrative
explanations sheet)
7/24/81 VI1-113 RCRA INSPECTION MANUAL
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FIGURE 18 9938.2
LAND TREATMENT CHECKLIST
1. Is run-on diverted away from the land treatment
facility? __Yes __No
2. Is run-off from the land treatment facility
collected? _Yes __No
3. Is the run-off analyzed to see if it is a hazardous
waste? _Yes __No
a. If the run-off is considered hazardous, how is
it handled? (Use narrative explanations sheet)
b. If it is not a hazardous waste, is it discharged
through a point source to surface waters? Yes No
(1) If yes, list NPDES Permit No.
4. Whet hazardous wastes are treated at the land treatment facility?
Subpart D Listed Wastes Characteristic Wastes (EP Toxicity)
A. For those listed wastes, were analyses done to
determine the concentrations of those constitu-
ents which caused the waste to be listed? Yes ^No
(1) If yes, what are these concentrations?
(Use narrative explanation sheet)
B. For those characteristic wastes (EP) Toxicity,
what are the concentrations of the following
Concentration (Mg/1) Waste
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Endrin
Lindane
Methoxyclor
Toxphene
2,4 0
2,4,5-TP Silvex
7/24/81 V!1-114 RCRA INSPECTION MANUAL
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5. Are food chain crops grown? _ Yes _ No
a. If yes, what are the concentrations of the
following in the soil and vegetation.
Soil Vegetation
Concentration (mg/1) Concentration (mg/1)
Arsenic
Cadmium
Lead
Mercury
6. Did the facility notify the RA that he is growing
food chain crops? _Yes — No
7. Is the following information kept at the facility?
a. Tests for the specific wastes and application
rates being used at the facility? _ Yes _No
b. Crop characteristics? __Yes __No
c. Soil characteristics? __Yes __No
d. Sample selection criteria? _Yes _No
e. Sample size determination? _ Yes _ No
f. Analytical methods used? _Yes — No
g. Statistical procedures? _ Yes _ No
8. Does the facility treat waste that contains cadmium? _Yes __No
a. If no, do not fill out b&c
b. If yes, was the pH of the soil and waste mixture
6.5 or greater the time of each waste application? _ Yes _No
(1) If the pH was less than 6.5, did the waste
contain cadmium concentrations of 2mg/Kg
or less? _Yes _No
9. Is an unsaturated zone monitoring plan kept at the
facility? _Yes — No
10. Does the plan include:
a. Soil monitoring? _Yes *|0
b. Soil pore water monitoring? _ Yes _ "0
c. Sample depths below waste incorporation? _ Yes _No
d. Number of samples to be taken? _Y«s _No
e. Frequency and time of sampling? — Yes _No
f. Analysis of samples? _Yes _No
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9S38.2
11. Are records kept at the facility of
a. Application dates? Yes No
b. Application rates? Yes No
c. Quantities? Yes No
d. Waste location? __Y*s __NO
12. Is a copy of the closure/post-closure plan kept at
the facility? _Jfes _Jio
13. Are ignitable or reactive.wastes placed in the
facility? __Yes _Jto
a. If yes, are the wastes treated, rendered or
mixed before or immediately after placement
in the landfill so it is no longer reactive
or ign-itable? _JTes No
b. Describe or attach a copy of treatment.
14. Are incompatible wastes placed in the facility? Yes No
a. Are the incompatible wastes placed in different
locations in the facility? Yes No
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FIGURE 19
CHEMICAL. PHYSICAL & BIOLOGICAL TREATMENT CHECKLIST
NOTE: Applies to treatment In other than tanks, surface impoundments, and
land treatment facilities.
1. Check treatment process and equipment:
a. Are there any leaks, corrosion or other failures
evident? _Yes _No
If yes, describe: .
2. Is the process a continuous feed system? Yes No
a. If yes, is it equipped with a means to stop
waste inflow (e.g. waste feed cut-off system
or by-pass)? Yes No
3. Is waste analysis information maintained in the
operating record? Yes No
4. If a hazardous waste is received which is substan-
tially different from any hazardous waste previously
treated at the facility, are the following obtained?
a. Waste analyses and trial treatment tests
(e.g. bench scale)? Yes No
b. Written documented information on similar
treatment of similar waste? Yes No
5. Does the owner/operator inspect the following,
where present?
a. At least daily.
1. Discharge control and safety equipment
(e.g. waste feed cut-off, bypass,
drainage or pressure relief systems)? Yes __No
2. Data gathered from monitoring equipment
(e.g. pressure and temperature gauges)? Yes No
b. At least weekly.
1. Construction materials of treatment process
or equipment to detect erosion or obvious
signs of leakage? Yes No
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9938.2
6. Does the facility maintain a closure plan? Yes No
7. Are ignitable or reactive wastes placed in the
treatment process? Yes Ho
a. If yes, is the waste treated, rendered or mixed
before or immediately after being placed in the
treatment process so it no longer meets the
definition of ignitable or reactive? Yes No
Describe or attach a copy of the treatment.
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FIGURE 20
THERMAL TREATMENT CHECKLIST
NOTE: Applies to thermal treatment of hazardous waste in devices other
than incinerators.
1. Is the process a non-continuous (batch) process? Yes No
a. If no, is the process operating at steady state
conditions (including temperature) before adding
hazardous waste? Yes No
b. Is a waste analy&is documented in the operating
record that includes
1. Heating value Yes No
2. Halogen content Yes No
3. Sulfur content Yes No
4. Concentration of lead Yes No
5. Concentration of mercury Yes No
NOTE: 4&5 not required if facility has written documented data that show
the elements are not present)
2. Does the owner/operator monitor the following when
thermally treating hazardous wastes? Yes No
a. At least every 15 minutes, existing instruments
which relate to the temperature and emission
control:
1. Waste feed __Yes _No
2. Auxiliary fuel feed Yes _No
3. Treatment process temperature Yes No
4. Relevant process flow _Yes No
5. Relevant level controls Yes __No
b. Stack plume (emissions) at least hourly:
1. Color (normal) __Yes _No
2. Opacity _Yes _No
c. Thermal treatment process equipment at least
daily
1. Pumps, valves, conveyors, pipes, etc • for
leaks, spills and fugitive emissions? Yes No
2. Emergency shutdown controls? Yes No
3. System alarms Yes No
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9938.2
.}. Is a closure plan maintained at the facility? Yes No
4. Is there evidence of any open burning of.hazardous
waste? (Use narrative explanations sheet) Yes No
5. Is open burning or detonation of waste explosives
conducted? __Yes _No
a.' If yes, is the detonation performed in accordance
with the following table?
Pounds of waste explosives Minimum distance from open burning
or propellents detonation to the property or others
0-100 204m(670 ft)
101-1,000 380m(l,250 ft)
1,001-10,000 530m(l,730 ft)
10,001-30,000 690m(2,260 ft)
7/24/81 VII-120 RCRA INSPECTION MANUAL
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VIII. OTHER ASPECTS
The following section addresses topics not already covered in the
manual but necessary for an effective enforcement system. The issues ad-
dressed here are: (a) referral inspections; (b) state oversight; (c) immi-
nent hazards; and (d) appearance as a witness.
A. REFERRAL INSPECTIONS
In carrying out its mission to safeguard the nation's environment, the
Agency operates under the authority of a number of acts in addition to RCRA:
The Clean Water Act, the Toxic Substances Control Act, the Clean Air Act,
and the Federal Insecticide, Fungicide, and Roaenticide Act. In order to
maintain the credibility of the Agency as well as the integrity of these
programs, RCRA inspectors should report all known sources of environmental
pollution to the appropriate Federal and/or State personnel for appropriate
action. The inspector should, therefore, do the following:
1. Be aware of the basic environmental requirements in other
media programs to which a specific source is subject.
2. Become familiar with readily observable indicators of envi-
ronmental pollution and any health or safety hazards when
making inspections.
3. Report all readily observable sources of environmental pollu-
tion and any health and safety hazards to facility personnel
and Inspectors.
In addition, EPA has joined with the Occupational Safety and Health
Administration (OSHA), the Food and Drug Administration (FDA), and the
Consumer Product Safety Commission (CPSC) to form an Interagency Regulatory
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9938.2
Liaison Group to coordinate the agencies' activities. Appendix V delineates
procedures for initiating referral inspections under the Inspection Referral
Program. RCRA inspectors, as representatives of the EPA, are responsible
for familiarizing themselves with these guidelines and insuring that obvious
suspected violations of other laws are not overlooked.
B. STATE OVERSIGHT
Under Section 3006 of Subtitle C, RCRA provides for authorization to
any State which has in existence a hazardous waste program pursuant to State
law and equivalent to and consistent with the Federal program. Therefore,
the EPA, as part of a State oversight requirement, will conduct inspections
of hazardous waste generators, transporters, storers, treaters, and dispos-
ers within States with authorized programs. The procedures for conducting
these State oversight inspections are the same as for those described in the
manual for routine inspections.
C. IMMINENT HAZARD INSPECTIONS
Inspections may also be conducted in support of Section 7003 actions,
imminent hazards. Procedures for these inspections are outlined in two
other EPA manuals, "NEIC Enforcement Considerations for Evaluations of
Uncontrolled Hazardous Waste Disposal Sites by Contractors," April, 1980,
and "Guidance Manual for Investigation of Hazardous Waste Disposal Sites,"
July 1980.
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D. WITNESS GUIDELINES
The role of a RCRA Inspector may include serving as a witness in a RCRA
enforcement case which is brought to court. The following-suggestions are
made to prospective witnesses in order to lessen the fears and apprehensions
which almost everyone has when first testifying before a board, a commission
or a hearing officer or in a court. Even those who have testified previous-
ly encounter a certain anxiety when called for a repeat performance. When a
witness is properly prepared, both with regarti to the subject matter of the
testimony and conduct on the witness stand, there should be little fear
about testifying.
It is of utmost importance that the witness be thoroughly prepared on
to the subject matter of the testimony. Only the witness can recall what
occurred in the field and why. Since many cases are tried substantially
after field activities are conducted, it is imperative that adequate docu-
mentation be originally prepared in order that a witness's memory may be
refreshed. A thorough and detailed review of all survey documents is the
only way prospective witnesses can be adequately prepared.
In order to assist witnesses on how they should conduct themselves, the
following suggestions are given.
The witness will be required to take an oath to tell nothing but the
truth. The important point is to remember that there are two ways to tell
the truth: one is in a halting, stumbling, hesitant manner, which nakes the
board member, hearing officer, judge or jury doubt that the witness is
7/24/81 VIII-3 RCRA INSPECTION MANUAL
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telling all the facts in a truthful way; the other is in a confident,
straightforwa-d manner, which inspires faith in what is being Sreid. It is
important that the witness testify in the latter manner. To assist a wit-
ness in testifying in such a manner, a list of time-proven hints and aids
are provided below.
1. General Instructions for a Witness
As a witness in a case involving testimony concerning the appearance of
an object, place, condition, etc., try to recollect by again inspecting the
object, place, condition, field notes and records, etc., when possible,
before the hearing or trial. While making such an inspection, close your
eyes and try to picture the item to recall, if possible, the important
points of the testimony. Repeat the test until thoroughly familiarized with
the features of the testimony to be given.
Before testifying, visit a court trial or board hearing and listen to
other witnesses testifying to become familiar with such surroundings and to
understand some of the things that will come up while testifying. When
testifying, be present in sufficient time to hear other witnesses testify
before taking the witness chair. This, however, may not always be possible
since, on occasion, witnesses are exlcuded from the court room.
Listen to the questions and then answer calmly and directly in a sin-
cere manner. The facts should be well known so they can be communicated.
Testimony in this manner applies to cross-examination as well as direct
examination.
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Wear neat, clean clothes when you are to testifying. Dress conserva-
tively.
Do not chew gum while testifying or taking an oath. Speak clearly and
do not mumble. Smoking will not be permitted while testifying.
2. Direct Examination
In a discussion on administrative procedures, E. Barrett Prettyman,
Retired Chief Judge, U.S. Court of Appeals for the District of Columbia,
gave the following advice:
The best form of oral testimony is a series of short,
accurate, and complete statements of fact. Again, it is
to be emphasized that the testimony will be read by the
finder of the facts, and that he/she will draw his/her
findings from what he/she reads Confused, discur-
sive, incomplete statements of fact do not yield satis-
factory findings.
During direct examination, stand upright when taking the oath. Pay
attention and say "I do" clearly. Do not slouch in the witness chair.
Do not memorize what is to be said as a witness. Prepare answers to
possible questions, but by all means do not memorize such answers. It is,
however, very important to become as familiar as possible with the facts on
which to testify.
During direct examination, elaborate and respond acre fully than is
advisable during cross-examination. However, when testifying, do not ramble
and do not stray from the main point raised in your lawyer's questions. The
taking of testimony is a dialogue, not a monologue. If testimony concerns a
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7 J ~> ^ • *
specialized technical area, the Court or hearing board will find it easier
to understand if it is presented in the form of short answers to a logical
progression of questions. In addition, letting the lawyer control the
direction of testimony will help you avoid making remarks which are legally
cbjecti-onable or tactically unwise.
Be serious at all times. Avoid laughing and talking about the case in
the halls, restrooms or any place in the building where the hearing or trial
is being held.
While testifying, talk to the judge, hearing officer or jury. Look at
him/her or their most of the time, and speak frankly and openly as to any
•'riend or neighbor. Keep your hands away from your mouth. Speak clearly
and loudly enough so that anyone in the hearing room or courtroom can hear
easily. At all times make certain that the reporter taking the verbatim
record of testimony is able to hear and record what is actually said. The
case will be decided entirely on the words that are finally reported as
having been the testimony given at the hearing or trial. Always make sure
to give a complete statement in a complete sentence. Half statements or
incomplete sentences may convey thoughts in the context of the hearing, but
may be unintelligible when read from the cold record many months later.
3. Cross Examination
Concerning cross-examination, Judge Prettyman gives the following
advice to prospective witnesses:
7/24/81 VIII-6 RCRA INSPECTION MANUAL
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Don't argue. Don't fence. Don't guess. Don't make
wisecracks. Don't take sides. Don't get irritated.
Think first, then speak. If you do not know the answer
but have an opinion or belief or the subject based on
information, say exactly that and let the hearing offi-
cer decide whether you shall or shall not give such
information as you have. If a "yes or no" answer to a
question is demanded but you think that a qualification
should be made to any such answer, give the "yes br no"
and at once request permission to explain your answer.
Don't worry about the effect an answer may have. Don't
worry about being bulldozed or embarrassed; counsel will
protect you. If you know the answer to a question,
state it as precisely and succinctly as you can. The
best protection against extensive cross-examination is
to be brief, absolutely accurate, and entirely calm.
The hearing officer, board, or member of a jury wants only the facts,
not hearsay, conclusions, or opinions. Testimony about what someone else
has told you will not be allowed.
Always be polite, even to the attorney for the opposing party.
Do not "be a smart aleck or a cocky witness. This will lose you the
respect and objectivity of the trier of the facts in the case.
Do not exaggerate or embroider testimony.
Stop instantly when the judge, hearing officer, or board member Inter-
rupts or when the other attorney objects to what is said. Do not try to
sneak answers in.
Do not nod for a "yes" or "no" answer. Speak out clearly. The report-
er must hear an answer to record it.
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9938.2
If the question is about distances or time and the answer is only an
estimate, be certain to state it is only an estimate.
Listen carefully to the question asked. No matter how nice the other
attorney may seem on cross-examination, he/she may be trying to hurt you as
a witness. Understand the question. Have it repeated if necessary; then
give a thoughtful, considered answer. Do not give a snap answer without
thinking. Do not be rushed into answering, although, of course, it would
look bad to take so much time on each question that the board member, hear-
ing officer, or jury will think the answers are being made up.
Answer the question that is asked—not the question that you think the
examiner (particularly the cross-examiner) intended to ask. The printed
record shows only the question asked, not what was in the examiner's mind,
and a nonresponsive answer may be very detrimental to your side's case.
This situation exists when the witness thinks "I know what he/she is after
but he/she hasn't asked for it." Answer only what is asked.
Explain answers if necessary. This is better than a simple "yes" or
"no." Give an answer in your own words. If a question cannot be answered
truthfully with a "yes" or "no," you have a right to explain the answer.
Answer directly and simply the question asked and then stop. Never
volunteer Information.
If by chance you answer was wrong, correct it Immediately; if your
answer was not clear, clarify it immediately.
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You are sworn to tell the truth. Tell it. Every material truth should
be readily admitted, even if not to the advantage of the party for whom you
are testifying. Do not stop to figure out whether your answer will help or
hurt your side. Just answer the question to the best of your ability.
Give positive, definite answers when at all possible. Avoid saying "I
think," "I believe," "in my opinion." If you do not know, say so. Do not
make up an answer. Be positive about the important things which you natur-
ally would remember. If asked about little details which a person naturally
would not remember, it is best to say that you do not remember.
Do not act nervous. Avoid mannerisms which will make it appear that
you are frightened or not telling the truth or not telling all that you
know.
Above all, it is most important that you do not lose your temper.
Testifying at length is tiring. It causes fatigue. You will recognize
fatigue by certain symptoms: (a) crossness, (b) nervousness, (c) anger, (d)
careless answers, (e) willingness to say anything or answer any question in
order to leave the witness stand. When you feel these symptoms, recognize
them and strive to overcome fatigue. Remember that some attorneys on cross-
examination are trying to wear you out so you will lose your temper and say
things that are not correct or that will hurt you or your testimony. Do not
let this happen.
If you do not want to answer a question, do not ask the judge, hearing
officer or board member whether you must answer it. If it is an Improper
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5938.2
question, your attorney will object for you. Do not ask the presiding
olficer, judge, or board member for advice.
Do not look at your attorney or at the judge, hearing officer, or board
member for help in answering a question. You are on your own. If the
question is an improper one, your attorney will object. If the judge,
hearing officer, or board member then says to answer it, do so.
Do not hedge or argue with the opposing attorney.
There are several Questions which are known as "trick questions." That
is, if you answer them the way the opposing attorney hopes you will, he can
make your answer sound bad. Here are two of them:
"Have you talked to anybody about this matter?" If you say "no," the
hearing officer or board member, or a seasoned jury, will know that is not
right because good lawyers always talk to the witness before they testify.
If you say "yes," the lawyer may try to imply that you were told what to
say. The best thing to say is that you have talked to Mr. ,
your lawyer, to the appellant, etc., and that you were just asked what the
facts were. All he wants you to do is simply to tell the truth.
"Are you getting paid to testify in this appeal?" The lawyer asking
this question hopes your answer will be "yes," thereby Implying that you are
being paid to say what your side wants you to say. Your answer should be
something like, "No, I am not getting paid to testify; I am only getting
compensation for my time off front work and the expense it is costing me to
be here."
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4. References
In addition to the above suggestions and guidelines, several additional
references are available for further background:
Expert Witness and Environmental Litigation, J. I.
Sullivan and R. J. Roberts, Journal of the Air Pollution
Control Assoc., April 1975, Vol. 25, No. 4.
Environmental Litigation and1 the In-Housc Engineer, F.
Finn; R.C. Heidrick; K. Thompson, Journal of the Air
Pollution Control Assoc., Feb. 1977, Vol. 27, No. 2.
Essentials of Cross-Examination, Leo R. Friedman, CEB
1968.
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9938.2
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APPENDIX I
ENVIRONMENTAL PROTECTION AGENCY
MEDICAL MONITORING PROGRAM GUIDELINES
-------
n " - £, n L. . A i
INV-RONy.ENTAL :3C7i:7::N AC--N'CV
?v 1SS3-81
MEDICAL MONITORING SROSRAK GUIDE.INES
7ne following i.-.fprr.ation arc attachments are intenoec for use 5y
Acercy caiRDoner.ts tr.at concuct occuoational meaical monitoring programs.
These" guidelines outline the sinimu.- assent: a 1 eleTie-.ts for such e prognr:.
anc snould net ae regaraec is seine ccffiprenensive. Seme Acer.cy worxplacas
may have potential exoosjre haza-ss that will reouira medical -mom ton n:
procedures net coverec in this oasic description; noweve-, ^t is esser.f.a'
that eacn local prsgriir induce »: least :r.e elerr.er.ts oes:r:oec he-em. ;«
more Federal reculation* and "ecomnencations aooetr for smoloyeas
potentially exDosec to tsxic cneT.ical anc :nys:cal agents, program uoca-ss
anc modifications ars to oe exoectac. When sue.-, cnances occur, they «n'i'i
be presentee by the Agency's Office of Occupational Hsiltn anc Safety.
Whc snoi.''C be iicluCec *n » -nediei'i monitsrinc
mecici-" mo'.'.to-mg oroc-arr is oesignec adsicsl'y for lesoratc-y
anc *ieli wcrKe"S wnose wcrv regularly poses the ?cssioil\ty of exposure :c
toxic ir.a:e-*e's. In edtfition, "tne prcgrarr. snsuli meet tne neecs of otne-
oiverse groups cf eralcyees wncse "jc:s rscuire orepJace-uent »r.c/o-
pe-iccic healt.i assessner.t. Ssne-e'ly, eoninistrative, f*. sea',
secretarial, statistical, anc other susoort personnel wno are exoosec t:
toxic mata-ials incirectly, mfrecuently, or inconseauer-tially snoulc net
be incluoec. Ke:resentative joi categories that snoulc have mecic:'
mor, -.tonne mace eveilatle on exposure include chemists, nncrooiolog'sts,
tcxicclogists, physical scientists, anc1 the technical personnel «*no
supoort tr.es e ciscip lines. Ensloyees who c:llect various tyoes o-
polluted sar.ples shoulc be induces if the sanpling rec-:ires exposure t:
pollutants significantly in excess of ambient concentrations. Mainter.ar.es
pe-sonnel normally snould be incluoed, since they are occasionally exposec
to toxicants at ur.expecteoly higr, concentrations, as should these wnc
perfprrr. eustocia' services in actual laboratories or in areas wnere toxic
materials are stored. Part-time and temooriry employees snould oe
includec if their jobs are similar to tne categories previously mentionec.
Tne decision as to which ernloyees are nominated should rest wit.n the
prograr. director or supervisor most familiar with tne possible h&zarss
Involved.
Is the eroeram voluntary?
Employees whose jobs justify Inclusion in the program have the option
to participate or not, with the exception of those few persons whose joos
reauire such examinations es a condition of employment. Future Agency
policy may expand the nuroer of job categories that wi':1 '
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9938.2
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9938.^
•-'•"——nt an: :e--:: : neaith issessme--.. i*ra--a"C£ inc-.catas t.iat
inciv-cjel has
cec'inec is saff icier-.. Oec'r.ninc ew^ayess sr.su'ic 5c •••nv::sc ts
?6r--.c-,oa*.3 recuiar-v if tney rema-n alioiS'ie fsr- tne ;rcc-tT.. £i:r.
fac::.i:y snoulc review its env.rg rgste'r pe-ioaical'iy ;o" assure tne
'^nc"i;sion cf til "at-risx" pe-sonnel.
Whs wi 'i 1 5i y
i] mcnitcr-.nc is the ressons-ioil-ity of tne smc'icye-, ino tne
Agency must &es- ir.e ent-.rs cast, wnen » p-esxist-nc cr non.joo-"eldteti
conc-.:ion is cetsc-ec in :he cou-rse of a hesltn ardent of Labor, Cffica of Vtcrsars1 Csroensation
Ccns^-itaf-cr is evjilatle from the Acency Cffica of O
neaitn anc Safety wnen jos-reietac illness is ceta:tso sr s^ssectac.
i*e s^vs-.c-ar se-v-ees
The fact that most t"i ooe-atiens are able to use ourcnese orcers tc
ootain loca" onysic'.an se-vicas s'.ro'i'.fies tftis proc-rement. Iceiny, the
pnys-.c-iar, cnoser. shoulc se boarc certifies :r, ocsucatiORal mecicine; how-
eve-, w.s is unrealistic because the numcer cf sucn physicians av»-;ie,:>ie
is cu-ita small anc most serve as f«- 11 -time program directors for large
incustr-a", ccrperations.
?sr the purpose of this prcgrarr., a local physician in a practice of
internal mecicine or in genera' practice will usually suffice. A physician
wnc oelcncs to the Americw Occypational Mec^cal Assaciefior, or a Iccal
occupational health society 15 prefe-r*c; tne names of these crysicians
nay be ootaines from the American Occupational «etfical Association, ISO
North wacke- Drive, Chicagc, Illinois 60606 (312/7S2-2166).
The Imoortant requirements are that tne pryslcien 1s caoecle, is
eauicaed to canouct a thorougn physical examination, ana has t high
Interest in the program. A local physician 1s in the best position to
orovloe a continuity of service over »e years and to handle referrals wnen
non-jco-relateti conditions are oetecte£. On occasion, local U.S. Puclic
Health Se-vice facilities are willing to perform this service. The use of
a reaeral facility generally offers an economic advantage and Is
encouraoec whenever such services ere offered.
-------
These se-vicas rcust oe pe-f;rr,e: 5y a clinice. larorstory that is
csroetsnt, -,s licenses, sarv.c'satss -r, \ aroficiency testinc ?racr»m(s);
anc T,ainti:ns r-.gcrous quality centre!. It should b€ ' ica.ise* :y :.ie
"scer»l ccve-nment. A nur.aer of li-re inte-st»te Ia5cr»tor:es s^avice
satisfactory sa-vica, r»oi2 turnarounc" »no reisonasle "'ess. 7rese laso-
ritcr-.es usually provice tneir own col'ecf.on anc sia^linc cantnners it nc
extra cost, anc'nost nave government "rates" tnat ar» comoetif.ve. Sines
tnese are la-ge laboratories, t.iey cm srsvios, it a -sssonasle ieC'.ticnal
cast, soecial'tests that may oe essertiil for tnose ereloyees *nc have beer.
exacsac to ssec^'iec cnemicals. Many ios::t»l ani locai laco^itar-.es :>•
s-coly only a portion cf tne lasoritsrv tests that may ae neeaec"; alss, :r.
psr-orzinc mar* com:lex tests, tnese hcs::tils anc Ia5cr»t:r-ss say cs
less r«naaie tr.an tne iarse interstate laaoritories that routir.e'iy car-y
out sucn procedures.
The local examining physician wi',1 be responsible fcr rsaue-tin:, in-
tsrpreting, anc evjluating laooratsry -esorts. A laocratory of tne pnysi-
cian's choice ^s crsferiole, prov^ced tnat it nests cuality and cost
sonas-lity stancarss.
efts" s.^cu-'i ex ar.' nations ae
Ioeany, tne periodicity anc content :r mor.:tor-ing exannnaticns snoi;lc
ae cetemnac by ar. eva'uafor, o- t.ie cc:ij=a.t:onaT risic; 'i.e., tne prcoa-
bility of acve-se effects of ex:cs-r«. When vie program was im'tiatac, it
was recsrneisec tnat an annual ax am nation suffice for most participants.
Until oetts- criteria are develooed frorr, a styoy of E?A ooeriticns ane
f;nc:ngs, an, annual evaluation is still rstonraenoec'.
Tne first, or baseline, exar.inatior. offered ta each participant snou'c
consist cf » complete meiical ex or.' nation. Th-.s wamination will ae -.•sef-.-'!
in orovicir.c reference informal-, on for the evaluation cf suosequer.t
pe-ioc:c exfcT.i nation finc-.nss. Suas«uer.t monitoring exar.inttior.s, for
most £?A ooe-stions, can oe of more li~itsc scooe.
Is tne 3r;c-»- a
Participants snould be advisee that this program of medical monitoring
examinations is not a direct substitute for "general cneckuos" or otner
periodic examinations oesigneo to monitor or promote genera*, health. Tne
occjoational aieoical monitor ing progran is designed to screen for evidence
of adverse effects of occuoational exposure, particularly exposure to
toxic suostances. Tne examinations do not provide A comprehensive health
evaluation; neither do they provioe significant screening for many of the
connon nonoccupational chronic disorders.
-------
MS:':;' esi---.£-.-cr
,r- rv :es*
9938.2
ars :c ccr.tinue ;o arovice
-ens'-s-va rasei.ne exarv.afon for new sa— .ic-iDar.ts -n tne procrj.ii *
prsv.se sar-.cc-'iC scrser.-.nc »«.-inaf.cns fc- etner car : i*
r*~;cz;z morii.snnc snculc '.ncluce, es a "immur, en Tr:e"im i
oc:j3ationel msiory review, e scrsemnc snysical examination,
O'ICOG anc ur:ns liooraiory tests (as c^scu-sses •selow), eno t anysi
evaluatior.. Tne men i tar ins extTination sncu:: oe SL'SDlefner.tec by
oures enc soec-.il tests on'iy as warrantee oy sxsosure t: specific si
cant ha:ar:s cr stresses.
tfhat »re t^e pas'c 1arori:;rv tssts :: :e irc'ucec fc- sac?
£acr. iniivicual sns-jli race we e Sesic canel c* £loc£ counts *nc
cnemist'ies ts evaluate &looc-r"orr.inc, kicney, liva-, »nc enoc-
cnne/tr-etdDcl ic runctior.. Tne rcHowinc sloe; tests sr« csnside^sc tc be
tne (r.ir.-.nrjr, ses'.racle:
• '«fn:te oiooc ceii count ani c>cff»renf.al cell count
• h'e'nsclocin ar.c/or hesiatsc-'t
« AloL-r.-.r, jiccunn, anc titi" prctein
t Tot2i bilinje'.n
• Seryr. elutan: szaiecet*.: trinsar.:nase (SGOT)
i Lactic eenycrocenase (LOK)
• Alkaline phcscnatase
* Calciur.
i Fhossr.oras
i Uric acic
• Crsetinjne
• Urea nitrocer.
• Cholesterol
• Glucose
Each employee should have a routine urinaiysis that consists of the
following:
• Specific gravity
l pH
• Microscopic examination
• Protein
-------
• 31uCSS5
What ;t.-.e- tssts arg
baseline chest x-ray should be a stancard 1-- x 17-incn 5-A
a^'-or-anterior) sxros'jre. The lateral view is not necessary ftr
routine screening purposes. The X-rey may be o&tainei from the examining
pnysiciar, a Iccal rsc-.olog'-st, er a local noss'.ta'. The f'-'iiT' snculc se
r»»c or '••viewec by * boar:-certif ied rac^olocist or oihe- comoetei:
mec-.cjl specialist. " Sussecjer.: oe-ioCic c-iest s-'riys S.IOL!: be ?epforme:
only -ner. cl'.mca1"/ ir.C'.csiec anc no: as a -sufne measure.
An electrocardiogram should be inc'-ufiea in the baseline ex ami nation.
I: or:inar:iy snouic'oe of :ne siancars 12-iesc rsstinc tyoe ir.c intsr-
pr?tec £y en inte-r.ist cr csrc'dog'st. Sucsecueni per-,oc-.c elec:rocar-
Ciocra^s snot-id be octiinec only wnen recommenced by the e*a.mninc
pnys'.cier. , enc not as a rouf.ne measure.
5ylp.or.ary fjnc::or tesf.r.c 's ses^rarle as a sart CT" t.is baseline
.insf.cn.* I: may oe '.nc-.ciwec Denoc-.Cclly *or eroloyees a*, rssoira-
tory syster r's<, sue." as these with sicn'.-'icart ejoosurs :: tsxi: custs
and" ir-i;»nts. As a mnimur., it snould" consist of sirale tests of luno
ver.f. laticr. : forcec exriratory vciume in 1 seconc (F-V. ) arc r'orcsc vi:a"
t>P,2^,Tv /ryr\
b£vCk*.bJr \ t «wy.
ec''a*i tests
i»orice-s whc are sicr-ificar.tly exoosec to certain designates mate'1! a is
require ac:*.tional ssecia' procedures in addition to the tasic panel of
tests. These tests are listed in Taole : and ere ootamacle at er. aoci-
t'onal c:st. The pnysic'.an should determine who is in need cf special
tests aftsr reviewing the history forss end after consulting with suoe--
visors ane/or medical ir.onUorino coordinators and health end safety
eesignees. Provision should be made for repeating tests wnen necessa-y.
Consultative assistance is available from tne Office of Occupational
heeitn and Safety regarding special tests.
Tests cropped f»sm IS/7 ouideHnes
The following tests, recsnmended in the 1S77 guidelines, art no longer
recaicnended as routine tests for occupational monitoring, either baseline
or periodic:
-------
is . 9938.
i 2eF"J~ sssc'msr for f-es:inc anc stcrsge
i reT.i:s :s-vicai cytology test '. 5ir tsst)
• Se-.'T slu-taric oy-jvic trar.sarv.nese (So?7)
• Se-j" trigiycsrices
t Serum sociurr., chlcr-.oe, anc potassium
• Car::no-8r.:ryo.piic antigen
Whet mes'ta' ~;r-t:-'.r,e records anc *:—?.« ars -ecu^'-e*?
gcr-ns
To provide uniformity of data collection and :o expedite ana-ysis, it
wouk be css-.ras^e is nave an £?& stancar: fom(s) for use -n mec'.cal
msmtsr-.n^ exarn na;:onj. However cssiraoie, this goal cces *
-------
cf si:r. -. -;r -,r.c :--ys':i" sxar:ina::crs i.ic ~ay os ".
•:£- "1, -s '"nc'Ci'-s: •*:- a'. 1 s-^ioyess ••:-". ir'.y s*:o«s: :: ••:.-. -.c'.
:sveis; •..*.,
S-nce tne ie=lv. *icr.".:ar-.r.s B-rc-a.T. ^^' ssiariisr, 2 se: ;•" rscc*:s ;•
vTCual cmzar.s, it ,TTJS: mes: ;ne -9CL'irsci«;:s cj me »--vec/ -c: c-"
(?.L. S3-5~S!. Zitt Sdrticisen1: :s rscu^rai :o -ssc inc S'.cn e cocy
of t.ne pnvecy S:z:6r.ent {A"ac."me.i- 3), wr-:n sx:idins :ie «ut.icr-'ty for
csllecf.nc tne inforr.acion, yses :s bs necs of t.".e T.fornat^sr., rylss cf
ccnf'.cer.tuiKy, anc sisciosurg infcrT.aiisfi. "ne or'cind'i sj tv.s s^et?-
msnt snoulc be -see ;zr: cf tne ST.: 1 eyes 's siec-.cjl .ton-::r-p.c -sc:-:s, ere
for seeing tr.at tne provisions of IMS Act ars met.
ssrts *nz scfc^
Th» ftxtmmnc ohysicun must :3nmur.*;c!t9 ail gxamnaf.on ''ncmes arc
ccimons tc Me "exa,-ines. In afiC'.ticn, tne «xajr.imr.c pnys'.c'an sr.au 1:
furr.-sh the Agency a writter r«sc-t on any sxan'nee «*'tn ^Tniincs :na:, tn
tne anys '.cian's cDinior., indicate en acve-se effect cf ocrjoat'.ona' exao-
sure. Th's -escr: snculc deta: 1 tne ccc^raf-anally rsla:ac fir.c'ncs anc
tne 34S1S fcr tne 9nys:c'.an's opinion. 7ne anys'.cun srculc ae :nstructsi,
no*«ve-, net t: -ev'sai any ssec'fic finches or fl'icncses unrslatss to
oc:--caticna; e^aesurs :n :ne reso-t to the Aoency.
On rscsict of suc:> a reDori, tne local mecical Bior.ltannj coor:'.na:3r
snail prsrstly sens a ceoy to:
Manager of ^eiicil Mcnircnnc
Office of Occupational heait.i anc Safety (PM-2?3)
401 H Street, S.w.
Wasninciar, O.C. 20^60
Loca? iranaflwient, safety officers, ani suse-visors snculc tise s
investicafive ans rer.scial action after oe'.nc aier-:efl :o a oossible occu
pational healtn anc safety proolem by a mefiica'i rssor":. Techr^cal assist
ance is availaole fram the Office of Occupational health tna Safety.
-------
OCCUPATIONAL JJDICAl QDISTIONSAlSI 9938
Fer Medisal Use Or.lv
Date
Ntre
(Us:) (7;rs:; (Jiissit)
Location
Regular Workplace ________^^^_^^^______^_________^^^^
(cuiicis; anc R.OOQ Susaer;
Job Title and CS Series Years is Present Jcb
^^^^^^^^••^^•^^^^^•^^•^^M^M •^^••^•M
Male [ ] fesale [ ]
Age __^_ Date of Birrs
Marital Starus: Marrieo [ ] Single [ J Separatee1 [ ] Divorsee [ ]
Please answer the following questions by cheeking cae applieaole b!
Rave you ever been hospitalized? No [ ] Yes [ ]
If yes, give details and dates:
Eave you ever had an operations)? No [ ] Yes [ ]
If yes, give details and dates:
Eave you ever been a resident outside the United States? No M Yes [ J
If yes, please iise location(i) tad date(s):
Indicate any job-related illnesses or injuries you have experienced
siace being tsployed by I?A:
-------
An annua'. nan-tonne ejafiineticn will be satisfactory far mcs:
Accitional special tests may be incicatac for tncse wor^s-s *no
have sign-;f icart wsos^res to chemcal or pnysicsl aoenis, in accaree.nce
'wnn OSnA or omer
Suestar.ss
Acrylonltnle
Inorcar.ic arsenic
Astestos
Senzene
Coke over emissions
Cotton oust
Dlcnlorooromoorcpwe
Inorganic lestf
Noise (&oove SS ££)
Organophospnate pesn'cioes
ests
Chest x-ray, fecal occult olood, procto-
signoiaoscopy
Chest X-ray, ssutum cytology
Chest X-ray, pulmonary function
Rei'culocyte count
Chest X-ray, julmcnary function, ssufjm
cytology, urinary sediment cytclocy
Pulmonary function
Soe-T, csunt (male), serum follicle
stiCyiatinc hormone, serjm lutam-'zing
hormone, serjtr total estrogen (female)
Blood lead, peripheral olood smear
morphology, blood Zinc protoporpnynn
Audiometry
Blooa cholinester&se
Pr-imata handler* should have an annual HS A? (hepatitis 6 surface
antiaen) test and & tuberculin test Unless known to be tuberculin posi-
tive).
-------
JO
P'.eisc =**£ * Use sf zzote >^;s;asces :.-.a: you nxacle i: your uorx.
5:^r ihose ir.c: particularly c-ncer^ you :ra= a nealir s;aeepov=:.
Do you have as? suggestions CD reduce ?ocet:i*i txposurts?
ladietce anf «7«peeaf ihac you hcvc tneriineed tiiic aifhe be due to
exposure ac werx aac indictee tiie suspected cause.
-------
la your work are you now or save you seer. ex?oscc to any of sae f si loving
agee:s ?
Exposure Preser.i Past
Inorganic fluorides [ ] [ ]
Lead [ ] [ ]
Benzene [ ] [ }
Coke eves eaissions ( ] [ ]
Inorganic arsenic [ ) ( ]
Metsylene chloride [ ] [ ]
Visyl chlorioe [ ] [ ]
Tolueae diisocyanare [ ) [ ]
Ixcessive aoise [ ) [ ]
Ni:rogen oxides [ ] ( ]
Crystalline silica [ ] [ ]
Nitric acid [ ] [ ]
Asaonia [ ] I ]
Beryllius [ ] [ ]
Paosgeae [ ] f ]
Allyl chloride [ ] [ ]
Asbestos [ ] [ ]
Susptct or known carcinogens [ ] ( ]
Pesticides [ ] ( }
laeteria or viruses [ ] [ J
Priaaee aniaals [ ] [ ]
Vibrating cools [ I [ 1
Lidiacion I ] I ]
-------
9938.2
Indicate ar.y Mood relatives vec ntve or nave had a=y of we fallowing:
3iseese Mst.-.er •»••«
Aaeria [ ] [ ]
Allergy (asthsa, [ ] [
eezesa, hay fever) [ ] (
Alconoliss [ ] [
Arthritis [ [
Sleeeiag disorders f [
Cancer [ [
Congenital calforsacioes { ] [
Diaoeees [ [
Saranysesa [ ] (
Epilepsy [ [
Claucoca [ ] [
Cou :: [ (
Sea::; attack ( [
High blood pressure [ [
Xidaey eisease [ [
N.id'.iey stones [ [
Cailblaecer disease [ I
Mer.cai illness [ j [
Mescal recsreaciar. ' ] [
Sickle cell disease [ [
Scacacr. ulcers [ [
S crone ( I
Tuberculosis [ (
If eiiser of your parents is oead, li
Mother died axe of
Father died ace of
X
r Crar
I
1
1
1
s t age a
eiatisr.s.-.i; te Me
::arsrt irct.-.er ;r ;;s:er .".%• Cr.ilsrer.
f ] f 3
I 1 t 1
] f 1 (
f J I ]
J I J I
• f
i i
[ [
[ [
: ) i
i i i
\ i
i i
[ ) ( ]
r j i ]
] ! [ 1
! I 1
j t r ]
f i ( i
i [ (
r {
i i (i
J I ] (I
1 I ] ! J
ec cause of deatr. , if 'cove:
re you aware of *ay diseases or illoesses iia: run ia your faciiy?
Tei f ] No [ J
If y*s, please list:
-------
i?A OMQ-4
Do you hive or are you concernee1 loou: »r.y of me
checit trie tsprcpr'.ate hex cr boxes.
[ ] Allergies
[ ] Back pain
[ ] Blood ia urine, sputus, o? icool
[ ] Blood pressure
( ] Bowel problems
[ ] Cancer
I ] Chest pain
[ ] Chronic cough
[ ] Cold or painful fingers
[ ] Constipation
[ ] Deacal or gum problems
[ } Depression or excessive worry
[ ] Diabetes
[ ] Diarrhea
[ ] Difficult? in sleeping
[ ] Dizziness
I ] tar or hearing prob less
[ ] Edeaa (foot or leg swelling)
[ J Eye trouble (other chan glasses)
[ ] Fainting spells or unconsciousness
( ] Fever
[ ] Frequant or stvcrt headaches
[ ] Frequent indigestion
[ ] Heart condition
[ ] Heart s&iraur
[ ] Eesorrnoids (:iles)
[ ] Hives
[ ] Ho: flashes
[ ] Kidney problers
[ j Joint pains
[ ] Leg crasps
[ ] Liver problems
[ ] Loss of meaory
[ ] Lung or breaking diffi:ulr
[ ] Kenopause
[ } Ku*cie aches or pains
[ ] Nervousness
[ ] Sexual problems
[ ] Sickle cell disease or rrt
[ ] Skin disease
[ ] Seooach pain
[ ] Swollen glands
[ ] Thyroid gland prsbler
[ ] Tremor of hands or head
[ ] Iiaers or cysts
[ ] Unexpected weight gain
[ ] Unexpected weight less
( ] Unusual weakness
[ ] Venereal disease
-------
I? A OMQ-7
9938.2
save yeu had or cc you aov nave ary 9- che fsllov-.-g illnesses S"
cone-:ior.s ? I* to, please =aec* trie appropriate biscud):
[ } Abnormal Sletdiag
[ ] AsetLia
f i ...... .. ,
L j AT _.!.._ 3
[ ] .ISCr.U
[ ] Cancer
[ j Cirrhosis of :>.e i;v«r
[ J Dersa:i:is
I ] Dizsiaeis or ftiacing
I J Isiiepsy
{ J £ry»i?e:*s
( ] CaUblaoder/'i cones
[ ] Claucoaa
f ] Concrrhea
! j Gout
[ ] Ear *«v«-
I ] sear: iicicx or :rout:«
[ ) Heoatnis
[ J Sen-.* or «?r;r«
[ \ Eigh blood ?re«aure
[ I Sives
{ ] Jauacie:
[ ] Stieney ^r
[ j Leuke&ia
[ ] XiUr:.*
[ 1 Migriine
or stones
[ } Ne?hri:ii (Brigni's disease)
I j Nervous br*
I
Paralyses oi *r
Piles or beaorrnoici
{ ?aeunoaia
I Polio
f ] SAeuMCic !«v«r
[ ] Scarlet fever
f ) Swollen ;cin:$
I 1 Ssreke
} luaereuioaii
j Ulcer (itosach or duodenal i
ON'.T:
N\»oer of prepiatici
Susser of li-»irg er-iliren
Number of cijcarr-.ag*j
Da:e of last
Cace of l*s: period
R*ve you had any uwiiual discharge e? bleediag is che pa«t cbr««
aetitas?
I*» [ ] He I ]
you reached ntaopause? T«* [ ) So [ J
-------
S?A
Do you ir-.a* ilcsr.clic »e
-------
9938. 2
Check if you have receives a=y of the fellov.sg, and give ap-rsxisa:e
vnes las: receivec, if le
[ ] Tetanus
[ ] Isflue^a
[ ] Typhoid
[ ] Dipntaeria
[ ] fceies
{ ] 3ubeiia (Ce—*=
[ ] Measles (Sueeoia or rei aeasles)
[ ] Yellow fever
[ J Sea 11
[ 3 ShoCAX (». iaBuae gloeulii)
! ] Issuae ie-.-o globulin !o? hepatitis
[ J Others (?le*ie list)
{ ] >Us:sux, pacer. :es:f or other skis cetc for
euoereulosis
Give dace and resul: of last cite, if ksove:
Dace Rewl: [ ] ?cji::*e ( 3
When you have finished this Mceietl rad Ocsupacioaal History fora, hand i
directly to th« doctor or writ, at, if mailtd, aam tnvtlept "To 3t Optaec Ocl
by Stcical Personael."
-------
T:OK sistoRY
Are you aov caking or have you :aice& »sy of tie following viwi
ticics [ ] Dexedrine
cr.e past-son:.-.
] Antibiotics
} Anticoagulant (blood tiianer)
j Accicepressants
] Aacihiscasiaes
] Appetite depressants
I ] Aanric
[ ] Ber.zedriae
[ ] Sirti csnrrcl pills
[ j Siooc pressure aedicacion
[ ] Coeeiae
[ j Cortisone or iceraids
List any drugs you talte regularly:
) Diuretic
] Eoraones
] Insulin or oral an;
] Laxatives
] Morphine
] Sleeping pills
] Suifa preparations
j Thyrcid
j Tranquilizers
,i-diaoe:ic dr^g
2ave you beer. or. tsy special die:(s) :i Me past year? Yes [ ] He I ]
If yes, describe type _______^_i^—_^—
ire you allerji: :o ar.y of she foiiovisg?
Pollens
Bouse dusc
A&i=al dander, feathers, or fur
Drugs
Vaccines
Sere
Mecal, jtwtlry
foods
Sucligh: or cold
If y«s, pltase lisc or provide detail!
-------
loaau* Joie U
IfmrHtK* ffian M Miwu
F»VJl II-M MM
'REPORT OF MEOICAl {XAMINA71ON
I W •»•«—«»TT •»l-*>ieU "»l
i oa
4. MIX «»
i Ik fr*a »H»«4T
n«c • rte« fift»a0T»
CJMICJL
• « •«• * >lf^ I* •••'•••>•*• ••
14 «*• »«d MCI MM
n UIMI M* on* /•««»
B •(*•' '
B. "***.-.-* r»lTT» '>«•»»«•»,
-------
?E?S:CIAA"S asz OKLY
Physician'i sussary »nc elaboration of all perzineas dita. (PhyfieitB
shall ceeesc en ail poii:-.v« answers. Physician aay develop by isterv-.ev
«r.y «
-------
Environments'. ?rc:sction Agency_ 9<3To -}
?r-,vtcy Statement
Oc:uoat'.onal Mecical Monitor-Ing Prccrarc Sec
A. Authority unaer whicr> tne Information is reauested:
ve Orcer 11807 wMcn reovires the: the Occupational Safe1:/
end Healt.i Act, P.L. £1-596 w.tn its stanoarcs, Caoe or" reoeral Pecula-
tions, Title 2S, Chapter XVII, Part 191C of tne Cocs of ?«oersl Regu-
lations be ac-oliec" to ?ede-i' eraloyees; Cooe of reee-al Regulations
Title 2S, Chaotar XVII, ?ir- I960, ?sae-»l Worice-s Sa:"s:y anc Healtn.
Dtner authority: r'M. Chdctar 339 (Hsiical exdmination for eoooint-
ment); F?M Chapter 752 (Aoverse actions); F?M Chaotsr S10 (Claims for
disability uncer worne-'s ccmse.isation) ; ??M Chaster e3i (Oisdbility
rstiremeit); ane ??M Chaotsr 32S.
:. Uses to be maoe of tne infor-nation:
The purpose of requesting personal infomation is to enable the
Agency Ociwat'.ona 1 Mesica'i Office*, wa/mninc pnysicien, anc" other
healtr. personnel to provice an occupational health program cirsctec
primarily tc protecting yc-- anc your fellow wcrxers from potential
hararcs in your worx environment ano tr.e recuctior of these hdiircs.
Tne rsc:r;; will oocjme-.t your health status, cnances in physical
cpni'-ticns throucr. we years, and provioe an account of any csre
renae-es, acvics "aiven, and consultations thdt are recsnwendefi.
This information may be used to determine unusual sascsotibility
to illness cr injury from wsosures in your wortc environment, to deter-
mine suitioi lity for assignments, tc oe-mit medical surveillance for
potential narsfu'i effects of toxicants usei in your worK, and to ero-
vioe mec'cal treatment ano «cv-cs. It may te used to plan, implement
and evaluate occuo&tional dnc preventive health programs, csncuct eoi-
demiologic research, tsscn, ana compile statistical data. It may be
useo to adjuoicate claims and determine benefits, and resort medical
conaitions required by law to Federal, State and local agencies. It
may be used for other lawful purposes including litigation.
C. Rules of confidentiality:
The information contained in these files will be ooen to review
and usage by the Agency Medical Office, the examining physician and/or
duly autnorized assistants except es noted below.
Information to be utilized for research, teaching, statistical,
or epidemic logic purposes will have all identifying data obliterated
and made unrecognizable as to the ioentity of an Individual.
-------
mrr 2.2
T: i«e
|M. owe* m*
' ^»<" •3HII
,*fm m ««••• -
11.
ITf« MBCMI
M 1*
iTtmi MI m'
M 1
l UN tMMffCM' «i «
i I
i I
I I
• I • I
I I I
I I
-------
cars :«y tne-«for« r,c: :e PCSST'S. j5'iy :" :***&'•* 5eie-"'ts nay
ir. tne lacx cf avzileoie '.nfc-me:'cn dscu: i.n srr
-scsivec « cssy :•" cms staisrre-,'. «*mcn I nay -?*.zir, arc I
'jt I may rscs^vs aocif.cp.a '• cssies y tr^s sti^aT-e-: user
recuest. I unoerstano mat e caoy of tr,:s stitasient rf^'il DC rlacss :n
my neilin -sc:r:s as avicenca of tm s nctif -.cition.
iypec or printac
ieia.
-------
A;
Tne r«c;rcs will ae. in tne local custoey af tne examining
cian and will ae rnaintainec :n i locxec fibne cacinet. Access'w.il
limited to tne custscian ancYor iu'y ssoointsd nealtn assistants. A
cooy of these reccrss may 5e ma-.r,taine£ in :ne Acency Occucar.onal
Mec''cal Cffics. -"ness w, 11 ae ,T.aintainefl in locfced cabinets with
access limits^ to the O'.rectar or ta autnor-.zed assistants.
Uoon destn, retirement, resignation, cr otner tamination of
Government se-vica, tne recsras will be fcrwjpiei to the US Of'ice of
Personnel Maneaerrient or Pufilic Health Service Ccmrnssioned Officer De-
partment of Personnel fcr inclusion witn :.ie Official Personnel
Records and the cystocy thereof will fall tc Che custodian ef sucn
recorss.
1 information aoout an apclicant, emo'ioyee or annuitant
snail not be maae availaole to the puolic.
Medical information about an aoolicant, emsloyee or annuitant T.ey
be disclosec tc the aoolicant, employee, or annuitant, or a repre-
sentat:ve oesignatad in writing, wcsat tnat medical information con-
cerning a mental or atner condition of sucn a nature that a pruoent
physician would hesitate to infonr, a person suffering from it of its
exact nature and prcaable outcome may be disclosed only to a licensed
pnysician designates ir, writing fcr tnat auroosa by the incividual or
his designated resrasentative. Tne determination on wnether informa-
tion falls int: tne purview above will rest witn the custocian.
me applicant, eraloyee, or annuitant may recuest release a?
recsrcs or information., anc'/or designata a representative, -in a lette-
directec to the custac*.an of the records. Tne reouest will give the
full name of the resresentative and indicate the reccras to be re-
leased.
0. Disclosure of information by participants:
Disclosure of the required Information is entirely voluntary ex-
cept for emaloyees for wnom disclosure is a condition of employment or
wne-e a medical certificate is recuired before assignment to positions
whicn involve: (a) ope-ation of motor venicles; (b) exceptional
stress; (c) food handling; (d) direct physical contact with people -
for example, nurses and physical therapists; (e) work aoove grouno
level or around hazaroous power-driven machinery; or, (f) strenuous
exertion or hazardous duty or physical retirements more arduous than
those described on SF-177 - for exanale, aircraft pilots anc flight
crew members, underwater divers, and firefighters. Pilots, flight
crew members, and divers will not be certified or recertified 1f the
Information Is not furnished. Other persons may decline to partici-
pate 1n or withdraw from the Occupational Medical Monitoring Program
at any time without prejudice to themselves or to their jobs. If the
Information 1s not furnished, however, a complete occupational health
-------
APPENDIX II
NEK'S PROCEDURES
FOR
CONDUCTING AN INSPECTION UNDER
A WARRANT
9938.2
-------
d. An affidavit is a sworn statement which, therefore, must
be either notarized or personally sworn before the
magistrate.
3. Draft Warrant
The contents of the warrant varies based on the type of
warrant sought (discussed below). The warrant should be
submitted in such a form that the judge or magistrate merely
has to sign it to make it valid.
a. Civil specific probable cause warrant • based on some
specific reason to believe that the requirements of the
statute or regulations are being violated. A civil
warrant sould be sought only where it can be accurately
stated in the affidavit that the purpose of the inspec-
tion is to find and remedy the statutory violation
through noncriminal proceedings.
Therefore, this warrant will be used when the inspection
is being made in response to the discovery of a poten-
tial or actual violation from another source, i.e., a
citizen's complaint or through the report screening
process. If possible, such a warrant should be obtained
rather than a neutral administrative inspection scheme
warrant (discussed below).
b. Civil probable cause based on neutral administrative In-
spection scheme. I.e., showing that "reasonable legisla-
tive or administrative standards for conducting an ...
Inspection are satisfied with respect to a particular
establishment." Marshall v. Barlow's Inc.. U.S.
, 90 S. Ct. 1816 (1978). A warrant based on a
neutral administrative process can be Issued only if the
facility for which the warrant 1s sought was selected
for Inspection through this neutral process. Therefore,
-------
9938.2
this type of warrant may be used for regularly scheduled
Inspections, e.g., annual inspections, post closure
inspections, etc.
c. Criminal warrant - obtained when the purpose of inspec-
tion is to gather evidence for a criminal prosecution in
accordance with Rule 41 of the Federal Rules of Criminal
Procedures. This type of warrant requires a specific
showing of probable cause to believe that evidence of a
crime will be discovered. It should be noted that,
oridinarily, evidence of a criminal violation discovered
under a civil probable cause warrant will be admissible
in court (see Section IV, Exhibit 1, p. 2). Therefore,
this type of warrant will be used only where the Agency
is reasonably certain that criminal violations have
occurred.
4. Securing a Warrant
The following procedures should be followed in securing a warrant:
a. When an inspector is refused entry, the inspector should
leave the premises immediately.
b. The inspector should then immediately contact the desig-
nated Regional Enforcement Attorney to inform him/her of
the situation. The inspector should at this time report
any exigent conditions; i.e., dumping, etc.
c. The Enforcement Attorney will assist the inspector in
the preparation of the necessary documents.
d. The Enforcement Attorney will arrange for a meeting with
the inspector and a U.S. Attorney. The inspector will
bring a copy of the appropriate draft warrant and affi-
davits.
-------
APPENDIX II 9938^2
NEIC'S PROCEDURES FOR CONDUCTING AN INSPECTION UNDER A WARRANT
In the event that entry is denied or consent withdrawn, the Enforcement
Division must be contacted. Normally an Enforcement Attorney will take the
necessary actions to secure three separate documents and submit them to the
judge or magistrate in order to obtain a warrant, viz:
1. Application for a Warrant
a. Statement of statutory and regulatory authority for the
warrant.
b. Identification of the site or establishment desired to
be inspected (and if possible the owner and/or operator
of the site).
c. Summary of the factual background for the warrant as
stated in the affidavit.
2. Affidavit
a. The affidavit should contain consecutively numbered
paragraphs which provide detailed descriptions of the
facts which support the issuance of a warrant,
b. The factual description should recite or Incorporate the
specific probable cause or neutral administrative scheme
which led to the particular establishment's selection
for Inspection.
c. The affidavit must be signed by a person with personal
knowledge of all the facts contained therein (in refused
entry proceedings, this person would most likely be the
inspector denied entry).
-------
9938.2
ii. The executed warrant must be submitted to the U.S.
Attorney for formal return to the issuing magis-
trate or judge.
iii. An inventory of any items which were taken from the
premises must be submitted to the court, and the
inspector must be present to certify that the
inventory is accurate and complete.
INSPECTIONS
The purpose of the site inspection is to obtain information, data, and
in some cases samples, to assess the problem and to develop the project plan
for a field investigation. If samples are collected, established sampling
methods and Chain-of-Custody procedures must be followed. The data from the
samples may be used in enforcement actions.
The investigation must be thorough. Do not attempt to rush through the
inspection. The inspection is complete only when the objectives are met and
the inspector is satisfied that all data and information have been collected
to assess the situation. A careful review of the field notes is required
before leaving the area to ensure that the objectives have been met.
Before the inspection is completed, the inspector should prepare a
«>ketch of the site, in the logbook if possible, locating fixed reference
points and locations of disposal and storage. If samples are collected, the
sample locations should be marked on the sketch. Inventory of visible drums
should be made where possible and also located on the sketch. The contents
of the drums will probably be different than the contents specified on the
labels; nevertheless, the labels nay provide useful information.
In addition to the drum inventory, the inspector should check for
sewers, drains, spills or liquid disposal and evaluate the runoff potential.
The potential for fires, explosions, and other imminent hazards should also
be evaluated. If the situation requires an emergency response, the Oil and
Hazardous Materials Coordinator in the Regional Office should be contacted
immediately. Observations of soils and exposed subsurface materials should
be made. However, care should be taken not to handle materials which may be
contaminated.
-------
e. The Enforcement Attorney should inform the appropriate
Headquarters Enforcement Attorney of any refusals to
enter and send a copy of all papers filed to Headquar-
ters.
f. The attorney will then secure the warrant and forward it
to the inspector; and/or the U.S. Marshall.
5. Inspections with a Warrant Should Comply with the Following:
a. Use of a Warrant to Gain Entry
i. If there is a high probability that entry will be
refused even with a warrant or where there are
threats of violence, the inspector should be accom-
panied by a U.S. Marshall.
ii. The inspector should never himself/herself attempt
to make any forceful entry of the establishment.
iii. If entry is refused to an inspector holding a
warrant but not accompanied by a U.S. Marshall, the
inspector should leave the establishment and inform
the Enforcement Attorney.
b. Conducting The Inspection
i. The inspection must be conducted strictly in accor-
dance with the warrant. If the warrant restricts
the inspection to certain areas of the premises or
to certain records, those restrictions must be
adhered to.
ii. If sampling is authorized, all procedures must be
carefully followed including presentation of re-
ceipts for all samples taken. The facility should
also be informed of Its right to retain a portion
of the samples obtained by the Inspector.
iii. If records or property are authorized to be taken,
the inspector must provide receipts and maintain an
inventory of all items removed from the premises.
6. Procedures to be Followed Upon Completion of the Inspection
i. Whoever executed the warrant must sign the Return-
of-Service form indicating on whom the warrant was
served and the date of service.
-------
APPENDIX III
ENVIRONMENTAL PROTECTION AGENCY
GENERAL - POLICY
TRANSPORTATION OF HAZARDOUS MATERIALS
9938.2
-------
APPENDIX V
INTERAGENCY REGULATORY
LIAISON GROUP
REFERAL INSPECTION PROGRAM
9938.2
-------
9938.2
20S3S
Federal Regjiter / VeL <« Nc. e: / F.-.dey. Mar£ 2£. 18E3 / Notices
regulatory tgencei which hive
responsibility fa- enforcaj laws to
protict hulls ud safety in the hose.
tht woricpiace. ar.d iht eswroMes-
Tiese agtsoei—CoBjtaer Product
Safety Cessation (CPSC). U.S.
Esviresscaia,' Protecaer Agucy {EPA.^
Toed ud Drag Adnuuinaoa (VDA).
ud tht food Safety ud Qualify Serv.se
(TSQS1. have jeaed together to develop
cocperaave pragras* that wi!2 proride
Baxacs public protecaoa while utag.
_.__--_- ..„_.,.-—, — --• mources ia Ihe soft cosMffesBvc •:„
Food Safety ud Qualify Service,-,!: L • ; mtnnfr . -.- '
^par»tatofAtBcdtu«(rSQ^frA^.:-.^tCc^ittoeit^£^OTeeBeat.- .
* Acnoie IcpleaeaiBDoa el lajpecaaa":. ^ '•• Work Croup hat luaaied a ausb«.* of. .,
Referral Progras."" •** ~\^*~~~A): the Food ud Ihag • J
. Zdtsca&oa ud Welfare (FDA): ud the • ~
.,- .-^ '••** .?-af theJRlC4»eaoM to di»oov«. TS;-H".
^uuuAsrr. Tail noticeTubliihes lac, .•^'.'^ aaUyze>ua correct poienaally -•-.?••••
pncecnres for uiaaaag juasil"^>*K'9»**-'^asardoas ctaaaoa*. A nujor afiort ef '
tupecaoaa. Tae Adnmunafiva^.^.'^fht yonp ha* bees the developaeat o!a"
JnctAut. Act (S UAC { SS3(b7) "*•* .-'? .progris to eeerdiaau the iaspeeaon •'*
provide* thai tit •oUduaon'of '^••.^r-^jcaofcafofthe five IRLGagneiek.-'
CB8i0a&ti ia aoiTvouirod af^adcfalr* v *•• "TaBtft afMBff hi*t cocpprrfff] * *J"%
•otBCiu far "nte^reuttveiulai. ^£-~ jnlornaHy for many yean. •rpeoaEy B
fueral tutasutt of policy, ailei of.? 'Jj»'" the area of eompiiaaa BipecaoavAa -
aicacy argiasaaoa. proadBrca. or /.':.., hupectotfrom oat agency aught have
pracact'. Zbe CILC ageaaa hrn-r-^,.. «b»erred a airaaBoc a the conw of •
dcuatned that thu JUfaaallairpccaa&r-mt&it-wbich appeared ts violate': '.£,-'
Progrue. nu'daaeejaatrrial hfli joJlida^g^iSothgaaeagy'i reqniremefft*. Saeh^l'
thu exesyaca^oa tht JnBqcirgagB^toj-^'.obiernacat -would bejaoied aad ^'T'-.~:
~ ' ~it public ccsseat. 2ioweveZ*B the Baited aloaj ta U»e appropnau agtacy'
ebttr%'at:o2i to the appropriate i
The deitrsuiation that actti
exin will be cade oaJy br ui ajtir; ..:
bt\inj Itctl luntdicnoa over the -.--,
tiupected vioJaeea. and thea eslr DC- •*
the bat:i of IU owa follow-up . '••
tavMUiiaon.
No laspector ii pcrsinad to es!fi.._f>.
areai of a facility or to pcrfora «sy"«^-
•cavitiei he would not enLaacilyado. "
dsriag the course of aa isjptsaoa-'-
• • aathorsad by the natutt hela '••:'
OBpowervd ta caforee. Howevez Jf-
danag us regular i&apccaoa he aoa
. observe, ia^plais view, t posaibV"
, J&fcaeaoaofaaetharafeaey'tbiwrr-
icgalaaoaa.^t Bay aou each at.' • "*
pobservaBoa aadjviarit to the *
appropriate aacacy.».....
cary ii during the «aune of u
BBthozszcB routuu taipecBoa. a "•".
potaB&al problea U <
eomei vader aaathe ageacy*! ''~
this progna require ao aadracsal - •"
• rattiory aathonty. ao ptracsilar •
'. QBABSceaasi will be aiadt ta tht*.
.•iacQiry at the start ef the hupeca'oo*-
.
iatereft o.'opez adsmissioa af.their^rzi'IarloIlow^p.JanccntyMn. tae ,v—-
*'^'' '
..,_....., aathosau. thi IRLC !"^VT-' .-V^agearyregional oficn here
accaoea wiQ Blow aiemtad ptwoas'tp^ladependeairy dcreloped cartaia
a&bsi: writtu cosaeao ittirdagth*^*: aerhimirt nch at chtckl — '
nfenl maptcacayrBgiaa tet ieaihia " ^a&d procedural gaidtuaev to kcQiQau
Uiinam. * '• --.*"i-««»«'r?^f/*HBiiHadof»««orftat'Ti»lRLCB.ie=i
Uiiaobc*.
ADDRESS: Wnnea eooacau ahould be
•denned ta Kit. SUMS CvBetttl
aad other Dutcriali to uaist
to aeaalasag iaipeeian to the
Exteaavt Aaiittu*. lataragcacy -••';_ ic^rinaasta of the other icfseiai.
Sffeet. NW. Roam 303, WashingtOB. • ...„
B.& VSSf. CesButa aay be enrmned
ta the KlCOSce located at the above *'
Moacty thrcughlbdjy.
•on ninxtn amRiuTWN o*. '*'*- '•
euimoNS eaMTAer. Ma. Saaaa
Cuaaeuv i
•e* eswti erTMt wonei eewTAen
laeuoy Aaiutaacc Of&ea. (TS-?M).
Ui. EavtranBBtal Pnusaoa Aftsey.
401XJ SrtiL SW- Wuharoe. D.C
9460: or taltpnone toll-free ax-424-
W6S or ta Waitiaftea, »*-l«04.
tU»HJ»tVT*«T OffGKUinOIC
I Ccaenl Back^rouad .
Tae iBtereiwcy Retalitorr LUi*n
Cfeup fDOC) U aad* op of lout Federal
• Tie ovenfl goal ef tht Refaaa] . ...
'iBtpectfoa Progna it to achieve early
ideatiScatfoa ud carman of meat
.prBbleBi.Bettaraaana|ofeompUuee •
BioiBaaoB at the field level wfll alae T
make Bare eSecave ut of liBittd
lasoscai IB BOBitBTi&g] OBBpua&ca by
thi regulated iadmnes. •
Ltfiaitioa mdSeopt
• fUfirraJ1aapecaonianda&atdu
iBtprnaBt by eat ifncy which may
mult a referrals of pottibit violtBeai
by oat agcacy to uoutr for follow-uo
tnx-tfjgtuon. bupecton fraa each RIG
agency will bt traced u racagaae
'•ttaaaoat which ladicate possible
vwlaaoat of other aaudtt' law* aad
ngulaaoat tad to rein nch .;
.
doM or dow aat odd cu oaJy be aadi
by the anacy aariaj •aiareaacat
•jwiadicaoa. Caaswrocatiy. the ia»e=E-~
willaotteteathcla&Urrefu -- v- ""
obtervatiaa that wffl be reftavd to -.•
• aaother ayeacy. A aatficabaa of the
• facSity by tat tajpeoor amid icjlr'tai '
tht obierwd rttoettan actaiDy ' '
fioaiamtn a Tialatea. thrfirsta^ht •
torttuu rtaedatl acaaa that it titaer
onaectwary oinnunect u a mul*.
fftaetafpccuraalceiartpeTUble -
ebeervatios. a nferaJ acsoraaeiB .
wffl be prepand which dwaibes tht .: .
obatrrattoa, iti loeaa'u. the aaat of tat
produet (If aay) awalvtd. tad tht ocam
•f the rMpeealble ccapaar oBdaL Tit'
caaaanadaB wtfl be forwarded w ta. .
.DU£ eaauet In the apptepnate aftac?
TaeaftacyTtcerrtaithereleail .
BMawrudaB wfll aaaeit It IB
eeafoBefioa with Its OWB priorttie* and
Ueate follower? tespec&oaa
accardiaely. Slact the iafpecter eaiai=f
wffl be airecitd toward the men lanoiu*
pnbleai which tht CtLG a|raaet
eaeocstar. ant nfcrnla are likely to '.
wanst • taily follow^p iaspecaoa by
the receives, tjtney. I! the rteti\v.g •'
cf taey b ainady aware of the proalca
aad ia twmn that tppropntit cerretiTe .
aea'oa ta alraady vadcrway. ao tanaar
would be raqiarid
-------
9938.2
• 'Federal Retfsier / Vol. 45. No. 62 / Fr.cay. March 28. 19BO / Notices 20639
Training
As istpeetcr triTir.g, prepic hit
bri: e«ve:opec wist; expbii^et
gccK/icine: of product a=d me defectt
•i;^ leserilly iscisaie* a violaoac o:
.tie: itnowi hasard.
Scse axt=;let of la* faad» e.' riiud
asi in.ipcr.ori will be trained to look
le-Vr help Uuinu what is covered, If
oimpede; obiervec1 «*r-»«i aesr.Ty,. -
fltby picetuing eqwpnoi erpctoadc
that ai^i'.stoe casi
iuptcftoni (e: tspiestnunac. Referral
and jus'. Tbi doriatr.i ouvtaej the
proeeiim ferisisasaj referral
laspecuer.* docuatau reined te Joe:
iaipccaoa wffi be uiucd at a lalar dau.
soa end Aa&erity T--"*
Tbe OU£ bai dtZiaed referral
lupecaoai ac - "'!•"*
• * ' laipmesi aoadaKri by oai
afcacy which ruuit la toiraberai eft
the pouib'Jiry of hit gitlnni a referral
obie.-vtaoi. Such aa ansocacese:!
Bty isply thai tht iuptRorhas btea
delegated euthoniy beyond that
coctaued IB the law he u acpowercd to
aaiorca.
i The Inspector wfll ester only thott
areaa. take then taaplei (ladcduzf
pbotetrapbi). or review thoit bookj and
recsrd* fer which he hai creimcrt
a. Should the taipeacr obierve e -
problea or tetfelarfty. ne wfll note the'
obserTBDoabaiaakeaofudgaest ... •
£! becaae <"-'"...
. ^_Tp7Aa/ny re(fiItaM3 Jor^^'watae uipertoaai waalo? tiothjU^.J-;
k^eb-^...r,m. ir^.i^M-'^-.^-- ••- taataaary aitaq tgrtt&nttoa whjsa.': *
caterWtiasf of fea=. KBB. of daad '7: * aiyincittdtobttrntionofmtarutto''-.-
icwn: lile in 0»e ncatty o.' wa«« ^UT'rt-*"*^**88^ •-"-*7T"'"*M*-??^""-'""''
• opea bosaj of etah pflec or • • Thebani forrafcnalhupec&finiii '
.5r«rb*Dy aotfy the owner, open tor.*?'
afenttB Tlrw> rYBB ^^ ***»« problea* an '.-.'— •'
«^^^u.-n_.i>. .-r not nnHer tie tBrjiieSaa oflhelawftl ••-.'•^B
If tht iBfpesur Ji ccrtau that the
ataa&an ht ha* «baerv«d •patai >b.' 'j'
•eriouahaardtthaalttnthf *-
lavucnaenl thaHaatdiate cjnu'jtt
•noa U BMHtary. the iacUity aay be
notified of tarproblea. (For axacpla..* •—
iweOe or bbwB cunad ieodi wmld - •
'^h«reB*idc»d«»e3nwprBalesi.-wtil*- •'
d eDcpevtrre.'T
t p
1 waictbt eafor
-
.••• • ..-• ^ •- -— . «- .
t JJfltes/ Ca/rf* :^j.; •>:'!:
''"
^o^JSSrS^aTSlw^^
aa oafttinx pnpvr'traaiac <
si BBC* :
ier. chaB8« and ' J"C ..«*?"?;.... --T-cr":*i>s^S?:'!. hit'of wnil «2abwhiciftaanSy*:"., .
iatary rcqorcscsa.. _ fiesote uidSaoot • • r^rf-'-- "* " ~'- connote potcsoal Tiolanoaj. The'hta " •""•
a.. ; fuyoteeadSoopt •' •itr
'
a&d wuju!&eu o.'rel«=»i*Tt*BiaB« r -
free Qe ptvpas will be ooDaoad Jroa
tht Rtipou fm uc u propaa .
:ajcaouhi.the
fimntt »«d
a=.j aatanali wffl be auetftd aad
imsiBu aadc band on Kteoaal '
progn.B wffi alto be eeniidutd at ftat
Cutdtliaea iar Refetnl iaepaetinai
Tht iBtmincj- Rcr^ttorr Iafoa .
Croup (ntLCl wai foracd to aert
doitly eoerdisau artTitjet bttwna
the L'Ji. Isrooaaental Proueaaa
Aftacy {EPAJ. Food tad Drag
Aisijictnor (TDA). Connaer
frodair. StJtry CeeaiitioB (CTSr,, tsd
Food iiifirx tod QuaJjry Scrnet (FSQS).
At pv. of IBM cocrdsated tQotl the
aftaott apted to coordinate thtir
cooplnna and aaforcaaeat proptai
aad idaeefied two fypct of eeopenan
of potenaa! noltaoai of other
Afeaoej' lawv Tht pwpoie of tht OUJC •
riftaiJ iniptrton profrae if to aak*
the proeaii aare iormal f\A to v-|v>**
tht laastrvlrjr of aach tfcseyi •
hvpt:t=n u ai&aaou which atybt
tndicatiTtof atenouhaardwillitil ..
aettV.r}'. Tat pngna it datipodio - .'
'tottfjeu with tht earcat optrabost of
the BU£ af caaet. The nftaml... *•
obaervaaen* will bt aadt pnaarfly at'
4hoie utabUatotau which aa mipeaar
(biTtj&fator) vulu ta tht aaraal eont
el hu laipacBonal werk-Tbry ooold
oJto bt aadt whflt oa oAoal doty froa
taui in tht pvblie daaaia. which an
not «nthia tht bcuodanei of a ptneulsr
aiu.
Coide (ApptsdixlV • ~ •'.'.-;
The KaiBiml Gcidefc only a
docsaaai. While tht product or tfta .
ntidianinDda
taitt tht aa>ar toco* of tht n/aml
projraav tht laip*etar ahould alto rater
lay other obaarwbani which aay ba «f
btinst to uothe tftncy. It b no: . .... .
annapattd that thtaapactar wfll- :.
eonnlt tht pddt doiai aaeh iaipoettaa, •
butthetotptetorahooldptaadically- _
ivntwmtiisttaftBnsanhli - •
faaillarlry.wtthtti ooataau. •• -.- \-,- :~
'
bch tf tee; wfl] bt rrtpoaifblt fer
tapltatsui the nftrrai profrtm
within its owe iBiptOoaal iwdalatt
aad authonrjr. Newrve. tit leUowuf
proeidvni thould bt foUowtd by all
cooperating actaoec
i. At tht floe of aarj-. the iupcctor
wfll TI*" no aABOsncBuat caBot&is
Tat nltstl
0) to tht atehasaa throath which
tnroraanoa cenccauai ptntacs*.
•bt evtbeu wfll bt ttusaittad troa
eat tftaey to anothe. Tu acao u
filled mi 0a/r who a ptrttnt
ob»erriaoa hu b«tn aada. aor for
•very tuptctton,
Tht atao eoaiiiu of two paru. Tht
opper peraon of tht atao prondtt
|U location, the aaat of tht product (If
-------
Federal Reprter ! VoL Q^ t^^ ^ p^. dwpowl DM.
ifginei. etafcaa o; ar IRLC reaaaal/ /* ^»n.» . • . ... ,J-'..,
mu eeasEriet&oas network,' »•' '••%'"*"- i Scmer nafioac tstfodaeaos of laadcd
dttesaabon ef Cvisug aeida. ud n- ju iue i vakieli nquinst vuaadad iti.'
rrttua&OC of pregns esphuu. k . ';. OBaHaeafr oa laadid pea? iaiaad cfla^e'-
•tpanfios for vucb cxptsiioa. T • • ;~ " jaBlfc dwcartad cttalx&c eoDvanaiu _ *
{udquinen end rtpoaal 1RLC wad - • tnim^er Saril*ioi7 UaUee Ctwp i*"-*"-
tad witi tieir tuu cwmtttptrti ID .-
cfiecore prepts BUVgeaeBU^ '
—s laada tht Ie3owia| • •. ^ -
;•""'-**..'"..-T-
baaeue OBBU&aaBoc b«a aaiaal ~"
). pMBadi mitutb aqepoaat
urbom don
i nw aatBui^ acmrml diwsw " • RIB Naai* Adonic
tist^. leadtBt daaaft, • •' " - ' r.
aadt^uw prDdaa labaiiaf
Cacno«fPnduesSoftyCetmtniuieo ..-7-.;
'• "-"
• 1 Lade ef child ntiftaat pa'eu .
pnpanBoa* w»b autbrl »*l»e^ia. . RatponM Noflficaut
'' A faOow
-------
ENVIRONMENTAL
PROTECTION ORDER
AGENCV
. 7 f
GBtERAl. - PQLIC:
TRHSrOSSTISN OF BgJCOGS MAIS3IAI5
1. KTfaCS£. Ciis Carder provides Asencwide policy on compliance with
the Hazardous Materials Transportation Act, 49 U.S.C. 1801-1812, and
the implementing regulations , 49 C.F.R. 170-179.
2. BAQQgJUNIi. As required by the Act, the Secretary of Trans-
portation has established eritsrla for handling hazardous materials.
No person nay offer or accept hazardous materials for transportation
unless that material is properly classed, described, pacteaeed, marked
and labeled. Persons snapping hazardous materials sust instruct their
officers, acsr.ts, and e=lcyees who are responsible for preparing
hazardous materials for shipment hew » comply with the lav.
3. APPIIOfllLiry. This crier applies to all organizational elements,
Agency employees and special Government ensloyees involved in the
teansport materials defined as hazardous in the Act and reealations.
4. POLIOT. It is EPA policy to piuLeii. the public health and safety
by ensuring that EPA eaplcyees properly prepare and ship hazardous
materials.
5. OBJi'^i7i. &is Crder requires the responsible Agency officials
to: fieveic? national guidance to assure compliance with the Acrand
regulations by each affected ytujiarn. inplenent ttis goidance, appoint
Safety Designees, icalesent training psujtaua, and review and audit the
effectiveness of tae Meney's efforts.
• ^^ ^7<^. »• ^*»
a. tesistant Administrators. Bach Assistant Administrator, in
tion with tne other AAs7"is responsible for developing national
for the respective programs to ensure compliance with the Act
and regulations, tte preparation cf this guidance will be
by the Office of Occupational Health and Safer/ and is more specifi-
•cally iS&cribed in Pmragraph 7 of this Order. S>ey are responsible for
ensuring compliance with the aeolicable national guidance and
•• i0p±emenefiuon>-ef-the- Uai..^' ^.uj.am for all elements under tbeir
•oraanisational jurisdictions.
Din: Imtitttd by:
-------
9938.2
-------
.> 7 JO •£.
ORD£*
Bie Assistant Administrator for Planning and Managejnent is the
Agency's designated Health and Safety Official and is responsible for
adsinistenng the health end safety ULOUIJIL. this progras is explained
in the EPA Occupational Health and Safety Manual.
b. Recienal A±ainistratars . B>e Regional Administrators are
responsible for ensuring coroliance with the national guidance
applicable to each reporting" unit tinder their organizational juris-
dictions and implementation of the training preqiam for effected
employees under their organizational jurisdictions.
e. Offieer-in-aarqe of Resorting ttiits. Cfficets-in-Ciarge of
Reporting Units I OICs ) are responsiaie for ensuring cacpliance with
the applicable national guidance and isplewentaticn of the training
prograra in their reporting units.
Jfcte: OICs are responsible for irolenenting the routine elements of
the health and -safety pru-iam at their reporting unit.--Sse.-EPA
Occupational Health and Safety Manual for a detailed description of
this yius.J— fciey are the senior official of any organization or
progran at a geographic location. Separate prograts or organizations
located at a ujinai site are separate reporting units. For exaqple,
tbe senior Surveillance and Analysis Division Official and senior
Office of Research and Development Official at a canton laboratory are
OICs at their respective reporting raits and Regional Jdtainistrators
are OICs at their respective regional offices.
d. Safety Designees. Safety Designees-aze responsible for
assisting we OICs, Regional Aaaiinistsattots and Assistant
Ad&inistratcrs with day-to-day iaplenentatien of this Order. Safety
Besignees are responsible for assisting employees in deciding whether a
vaterial has been classified as hazardous for purposes of
transportation and what the raquirenents an fas shipping, package
labeling, etc.
«. Director, Office of Oeajgatienal Bealtfa and Safety. Onder the
supervision of tbe Assistant Acsonistrator for Planning and Management,
the Director of the Office of Occupational Health and Safety (0025) is
ctsponsitole for:
(1) Reviewing the proposed national guidance for each affected
7a(2)..
TARS -2-
«M IIII.1SI '»-«'
•»* •!••!<«
-------
°«D£« 1000.
(2} Developing, or reccnnending, and coordinating courses to
'train Agency personnel, see subparagraph 7c.
(3) Reviewing, monitoring, and auditing the effectiveness of
Agency compliance and informing the responsible Agency officials of
problem areas.
(4) Znfoming the Assistant Adainistrators of amendments or
revisions to the Act and regulations.
7. KOQ13UH55 PCS
a. National Guidance.
(1) Each Assistant Administrator, in cooperation with the other
Assistant Administrators, will develop specific procedures to ensure
compliance with the Act and regulations. Standard operating procedures
nay need to be modified to incorporate these procedures. The Office of
Hazardous Materials Operations, Depamunt of Transportation (Q££) can
be consulted for technical explanations and information.
(2} Bie COS will review these procedures for general
coisliance with the Act and regulations and for uniformity between
ptouraM where possible. Insofar as possible, uniforn, specific
procedures should be developed by the affected piUjiai'is.
(3) After GOES review, the piuyram offices should acquire the
approval, or concurrence, of the GEMD to be certain that an employee
wbo follows the proposed procedures will be in compliance with the Act
and regulations.
(4) Any procedures approved by the GBD will become national
guidance for that progmi.
(5) OCBS will distribute the national quidence to all
esployees who night reasonably be expected to authorize, supervise,
direct, handle, prepare, or offer hiiTnrrtcm naterials for shipment in
b. Safety Desienes.
(1) The responsible Agency officials should appoint Safety
Designee(s) to assist with the day-eo-day iaplenentation of the Act,
PAR 6 -3-
i*A !•*•
o»o
-------
1000.
the regulations, and the national guidance, (see Occupational Bsaith and
Safety "Manual, Qiapter 1, subparagraph 5b(4)).
(2) She Safety Cesignee should be thoroughly fanilar with the
Act/ the regulations, and the national guidance as well as possess the
requisite scientific and technical taowledge to interpret the
requirements .for Agency employees.
(3) All involved esplcyees nust be inforned of the name and
telephone nurier of the Safety Designee for the reporting unit.
(4) The Safety Designee will be available to advise employees
on the proper classing, describing, packaging, aarfcing and labeling of
hazardous materials, etc.
(5) In the ever.t of an emergency or a unique question of
applicability er interpretation of the Act, regulations, or national
guidance, the Safety Designee should be consulted.
e. Training.
(1) The Agency* will provide a training pruuian for Agency
er^lovees who authorize, supervise, direct, advise, handle, prepare, or
offer' hazardous materials for transportation in
(2) All such employees should be trained to: understand their
obligations under the Act, the regulations, end the national guidance
for the respective prograns; coqpiy with these requirements.
(3) The training pnxfran nay be tailored to meet the
individual needs of the office, regions, reporting unit, or en=doyee.
(4) No employee should perfonn or be requested to perfect
official duties involving the transportation of hazardous rater iais
unless property trained.
d. Overview.
(1} She COBS viU ronitrr and review periodically Agency
eonpliance with this Order.
(2} Probleas win be brought to the' attention of the
responsible Agency officials for correction.
PAS 7 -4-
-------
ORDER
1000.
8. SAVacs PROVISIONS. Qianges in the Act or regulations which occur
after tne effective cats of this Ocer win autonatically cone under
the purview of this Order on thoeuective
PARS
-5-
f » A • »-
c :
i -i
-------
9938.2
APPENDIX IV
DEPARTMENT OF TRANSPORTATION
HAZARDOUS MATERIALS TRANSPORTATION
REGULATIONS
-------
9938.2
DEPARTMENT OF TRANSPORTATION REGULATIONS FOR USE
OF HAZARDOUS MATERIALS TABLES AND FOR COMMUNICATIONS
(49 CFR 172; 41 FR 42369, September 27. 1976. as amended by 41 FR 57020. December
30. 1976: 42 FR 22366. Mar 3, 1977; 42 FR 28848, Jane 6, 1977; 42 FR 34283. July 5.
1977; 42 FR 57964, No»ember 7, 1977; 42 FR 58522, November 10, 1977; 43 FR 970,
JanBary 5,1978; 43 FR 10917, March 16. 1978; 43 FR 17942. April 27, 1978; 43 FR 24*45,
loot 8,1978; 43 FR 39788, September 7,1978; 43 FR 48641, October 19,1978; 43 FR 57897,
December 11. 1978: 44 FR 9756. February 15. 1979: 44 FR 10984, February 26. 1979: 44
FR 22467, April 16, 1979: 44 FR 25238, April 30, 1979; 44 FR 70721. December 10,1979;
45 FR 13087, February 28. 1980; 45 FR 34560. May 22,1980; 45 FR 43761, Jane 30. 1980;
45 FR 46419. Jul> 10. 1980; 45 FR 49939. Jul> 28. 1980: 45 FR 62079, September 18.
1980: 45 FR 68653, October 16. 1980; 45 FR 74640, November 10, 1980; 46 FR 5298,
Januao 19,1981; 46 FR 9880, Januao 29,1981)
IT1«I2
215:0111
PAIIT ITS-HAZARDOUS MATERIALS
TABLES AND HAZARDOUS MATERIALS
COMMUNICATIONS REGULATIONS
Thur
Furpav and Kept
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t«M*n O-tttftMB.
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EXPLOSl'v'Ei A award
EXPLOSIVES B Marc
•LASTING AGENTS pucwa
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ITUI!
ITTST IICIFOUM itaiitfonB far araut oto-
evaimfuan
mja NONFLAMMABLE CAS i
in.;):
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in. MI
ITU JO
FLAMMABLE GAS MKVC
CHLORINE MCVC
POISOS G«3 BttOrt
FLAMMABLE MMV4 u* Befefeuan
COMBUSTIBLE ptacuc we noaifaun
FLAMMABLE SOLID toon
FLAMMABLC SOLID * •uar*.
OXIDIZE*. Mare
0*GAMC PEROXIDE I
AmWDUCB-D
APPENDIX C-DHMBOMJ mnnanon
Ttta Firt Uiti tad cteatta
IA* OnATGBMBt Of T»MU>
ttali
ppofldtd tar IB
cu 9!
MutS pefom OH ftme-
1171.101 Pwvetc and ate of bacardoas
•uutteb lAMc
|45 FR 34560. Mat 2. 1980. effeeiivt
November 20. 1980]
(at The Hazardous Materials Table
(Table) in ihu secuon denaaates the ma-
tenab luted them u haurdous maunais
for the pureoie of mniporuubn of thwe
matenalf ID commerce The Table idenu-
fia the dan of each luted material, inti
tpeafte or reference requirement! m
OH fubchapter penaunnj to m packatvit.
kbebna. tad truoponauoo
(b) Coltmui I coaiaire ihe four lymboli
at appropriate: Wiu ( + ) and thc'leucn
"A". "W. ud "E".
0) The pltu (•) fixes the proper ihip-
pu« oaoc and the hazard dau for thai
entry without retard 10 whether the ma-
terial meeu the definition of thai dasi
An alternate proper shipping aamt and
hazard dau may be authorized bi the
Aaieoaie Director, Office of Hazardoui
Matenali Reeulaaon. VTTB.
(45 FR 14640. Nov. (0, I9SO. effective
Nov. 20. IKO]
(2) A tetter -A" renncu the appba-
tJoa of uui ubchapier to matcnati eeni
eampened by mrcnft. but a tetter "A"
hat BO Braincaace or effect when—
(i) A taer "E" abo appean with it
and at mawM b a haardoui tab-
-.or
. The material a a haxartoui wane.
(3) A tatter "V rcRhcu the appbcuoa
ef OB nMazur to materials bemi nwu-
ned by mid. but a truer. "W" has
•CBifirancf or effect when—
(I) A kner T" abo appean with it and
the material B a hazardous tubnance. or
(if) The natenal is a hasardoui wain.
(4) A kner "E" tdenufie materials
•hjch art aubjcci 10 the raqiurcmeou of
Ihu BirrhtpifT. ntardkai of the mode of
•twitted w/ m mniMi OP NATUWAL ATTARS, we.. VABQHCTON. B.C. MCB? ••> m.iot»»oj r
-------
215.0112
HAZARDOUS MATERIALS TRANSPORTATION
tnuuponaiion or hazard clau. if it u •
hazardous lubtiancc (u denned in {171.1
of uiu subchapier) A hazardous substance
which doe not met; ihe denning cniena
for mother hazard clau remains subjec.
to certain requirements of this nibchapter
ai an ORM-E
(c) Column 2 lins the proper shipping
name1 of materials designated as hazardous
mttenals. Modification of a proper ship-
ping name may otherwise be required or
authorized by this section (sec Paragraphs
(bX4i. (cXIO). (ex 11). (cX12) and (e)(13)
of this section) Proper shipping names
are limited to those shown IB Roman type
(not italics)
(1) Shipping names may be used in the
angular or plural and in either capital or
lowei case letters.
(2) The words in italics are MI pan of
the proper shipping name but ma> be
used in addition to the proper shipping
name. The word "or" ID italics indicates
that any terms IB the sequence may be
used as the proper shipping name as ap-
propriate.
(3) The abbreviation "n.o.i ", which
means "not otherwise indexed", or
"n.o.i.b.n.". which means "no- nherwtse
mdexsd by name." may be used inter-
cnanixably with "n.o.s ".
(4) Except for hazardous wanes, when
qualifying words are used as pan of
proper shipping name, their sequence on
the piickage marking! and shipping paper
descriptions is optional However, the
cnir> in the Table reflects the preferred
sequence
(!) Except for organic peroxides, when
one eiiry references another entr> by use
of thr word "IK. " if both names are ID
Roman type, either name may be used as
the pioper shipping name (e.g.. Carbolic
•ad. Stt Phenol) For an organic peroxide.
the technical name shall be used as the
proper shrpping name.
(ffl The words "pouoo" or "poisonous"
in this column refer to materials that
would cause death by lyiiemic poisoning
nther than by corrosive destruction of
tissue.
(7) When a shipping name includes a
eoaoainoon range as pan of the shipping
description, the actual eonoennnon bang
shipped, if it is within the range stated,
may be used IB place of the concentration
unit. For example, a hydrogen peroxide
solution containing 30*i peroxide may be
•hippiri as ether "Hydrogen peroxide
solution (8*» to 40«« pcronde)" or
"Hyarotn peroxide ionium. 30* per-
oxide."
(8> The osc of ihe prefix "mono" to
opoocal in any shipping name when ap-
propriate. Thus, Monoeihanolammc may
be innd interchangeably with Eihanola-
mute, la "Difluoromooochloronhane"
the tern "mono" is considered to be a
prefix to the urn "chloroohane" and
may be deleted.
(9) The numben in italics following a
•roper shipping name of a material
iaennfied by the letter "E" u Column 1
ipeafy. ID pounds and kilograms, the
minimum quantity of the material that
eoiuaiuies a rcponable quantity, ex-
dudinii water and other formulating
materials For example Ammoois solu-
oon. {RQ.IODO/4H) meant thai the
rcponable quantity for the Ammonia is
1.000 pounds or 454 kilograms An>
formulating material that is identified by
the Inter "E" in Column l of the Table
to {172 101 and used in a mixture or
solution must be evaluated independently
for the RQ determination For example.
if Mevtnphoi (KQ.J/0 *5*) is muted with
Xylene (HQ-IOOOHW and is in a 10 Ib
package described as "Organophosphorus
ptsuade. liquid, n.o.s.". Mevuiphos.
could be in a rcponable quantity, but'
there could not bca reponablc qtunuit
of the Xylene present in thai package.
(4.* FR 14640. Nov. 10. 1980. effective
Nov 20. I980|
(10) If the word "waste" u not in-
cluded in the hazardous material des-
cription in the Table, the proper shipping
name for a hazardous waste must include
the word "Waste" preceding the ship-
ping name of the material. For example
Waste acetone
(45 FR 74640. Nov. 10. 1980. effective
Nov. 20. 1980)
(I!) A mixture or solution comprised
of t hazardous material identified in the
Table by technical name and oon-
hazardous material may be described
using the proper shipping name of the
hazardous material, if—
(45 Fit 74640. Nov. 10. 1980. effective
Nov. Z). 1980]
(!) The mixture or solution is not spe-
cifically identified in the Table;
(ii) The hazard class of the mixture or
tohiDon is the same as that of the hazard-
ous material, and
(iifl The qualifying word "nurture" or
"solution" as appropriate, is added as
pan of the proper shipping name. For
example, a solution of Acetone, mineral
oil. and water, meeting the definition of a
flammable liquid, may be described under
this optional provision as "Acetone solu-
MB, Flammable liquid. UN 1090."
(12) ".curved]
US FR 74640. Nov. 10. I960, effective
Nov. 20. 19801
(13) Except for proper shipping names
in the Table that are preceded by a plus
<*)—
(0 If h is specifically determined that
a material BMW the deflation of a hazard
dais other than the class shown in aaooa-
DM with the proper shipping name, the
material BUR be described by an appro-
priate shipping name fined ta anoaanon
with the correct dais for the material or—
(U) If an appropriate technical name to
not shown ta the Table, selection of a
proper shipping name nun be made from
or B.OJ.
n.o.s entry, such as "Corrosive liquid.'
B.O.S "
(iii) If a material meets the definition
of more than one hazard class, and is not
specifically identified in the Table, the
hazard class of the material must be
determined by using the precedence speci-
fied in 1173.2 of this subchapter. and an
appropriate shipping descnpuon must be
selected as descnbed in paragraph (O(I3)
(u) of this section
(iv) If it is ipecificallv determined that
a material is not a forbidden materui and
does not meet the definition of any hazard
dais, the matenai u not a hazarooi:s
material
(d) Column 3 contains a designation of
the hazard class corresponding to each
proper shipping name, or the word "For-
(I)A matenai for which the entry ir.
this column is "Forbidden" u prohibited
from being offered or accepteo for trans-
ponanon. This prohibition does not applv
if these materials are diluted, stabilized.
or incorporated in devices and they are
classed ID accordance with the definitions
of hazardous materials contained in Pan
173 of this subchapter.
(2) When re-evaluation of test data or
new data indicates a need to modify the
"Forbidden" designation or the hazara
dasi specified for a matenai specificalh
identified in the Table, this data should
be submitted to the Associate Director.
Office of ""•"*"•" Materials Regulation.
0) Notwithstanding the ORM class
shown for a matenai in Column 3. such
a matenai having a flash point of 100'F.
to 200*F. is dassed as Combustible
liquid when in a packaging having a
rated apiary of more than 110 gallons
(4S FR 74640. Nov. 10. 1980. effective
Nov. 20. 1980]
(e) Column Ma) lifts the identification
numbers asnped to hazardous materials
Those preonaed by a "UN" are associated
with descriptions coandered appropnate
for tmenauonal shipments u well as
domcs&c smpmentt. Those preceded by an
"NA" art associated with descriptions
that arc not recognized for international
shipments, except to and from Canada. If
an identification number is in the
"NA9000" series, it to ether aawoaied
wnh the description of a matenai that is
not appropriately covered by mumational
hazardous •"••*"'• (dangerous goods)
shipping standards or not appropriately
j by such standards for emergency
information purposes, except for
the United States
cormpooding to the specific heard i
of the matenai beuig shipped. The
that mon appropriately dacnbes the
material must be used e.g., an alcohol
not luted by name In Ihe Table must be
shipped as "Alcohol. B.OJ." rather than
may be more appropriately described ac-
cording to their application, such as
-Compound, deamng. liquid" or ••Com-
pound run removtai." nther than by an
Chemical Regulation Reporter
(I) cohom 4 specifies the labels required
to be applied to each package, subject
to the additional labeJiaz requirements in
IJTZfO.
(g) Column 5 references the applicable
partnging section of Pan 173 of this sub-
chapter. Excrpuons from some of the re-
quirements of this wbchapter are noted
ta column S(a). Other exceptions relating
to the specific mode of transportation are
contained in Para 174. 173.176. and 177
of this subchapter. Reference to specific
packaging rcquBtmenu and certain addi-
9JM.in.iotM jt
-------
COMMUNICATIONS
21S:01U
tional e-tcep'tons ve noted in column
50».
(I) Each reference to > section in
Column S(b) for an ORM A. B, or C
thai is a hazardous <* ie or a hazardous
nibiianct 11 modifiec » rtad {1*3 S10 if
the tcciion referenced 11 applicable only
to 1 particular mode (or mode) and the
material n transported b> a mod* noi
addressed m the section
US Fit 1*6*0, No*. 10. 1980. effective
No. 20. 1980)
(h) Column 6 specifics the maximum
net quantity in one package for transpor-
tation b> aircraft or pasienger ratlcai In
this column. "Forbidden" means the
matenal may not be offered or earned
and is limited in its applicability onl> to
the types of innsporution covered by
the column. In addition, an exception for
certain flammable liquids is provided IB
1173.118 of this siibcnaoic:
(I) Column tXD spec fie the maximum
net quantity permitted in one package for
mnsponauon by passenger-carrying air-
craft or passenger railcar For transport!-
oon by aircraft, any material forbidden
OB passenger-carrying aircraft but per-
ntud on cargo aircraft, or which exceeds
(he maximum quantity authorized on
passenger-carrying aircraft, emu: be
shipped by cargo-only aircraft and bear
the CARGO AIRCRAFT ONLY label as
described in {HZMt-
(2) Column eXb) ipeafia the maxunuro
on quantity permitted in one packicc for
transportation by cargc-oruj aircraft
When offered for transportation b> air-
cnft. a package must bear the CARGO
AIRCRAFT ONLY label when the quan-
tity of hazardous material in one package
exceed* that authorized on passenger-
carrying aircraft, or is forbidden OB
passenger }•• means the material may be
(towed "under deck" u a companmeni
or bold subject to the ttquiremenu of
1176.6X0. When both "on deck" and
-under deck" an authorized, "under
deck" should be used if it a available.
(3) ••}" meant the material may be
stowed "under deck my from beat" in
a ventilated comparcnni or hold subject
to the requirements of 1176.6X4) of this
mbchapter.
(4) ~4" means (he material is authorized
to be muported in only (he homed
quantme specified IB the CFK MCOOD
fcuri m Column 5 and n subject to the
Howage ncnaremenu specified for a cargo
wand for the tame matenal.
MT41 •ubMhrM by THE
N,
(5) "5" meant the maienal u forbidden
and ma) not be offered or accepted for
transportation
(6) "6" means the matenal is authorized
to be transported in t magazine subject
to the requirement! of ii 176.135 through
176 144 of thu subchapier
0) If any entry in the Table is changed
by an amendment to thu subchapier,
such a change does not" apply to ihe
shipment of any package Tilled pnor to
the effective dtte of the amendment.
unless specifically stated otherwise in
the amendment or the "Effective date"
enir> in its preamble
5 FR 74640. Nov. 10. 1980. effective
lov.20. 1980)
(k) Exeep; for hazardous substance
and hazardous wastes. Amendment No
172-58. to the extent that it require a
change in the shipping name or dats of
a matenal. applies after June 30. 1981,
|45 FR 34560. May 22. 1980. effective July
1.1981]
Hazardous Materials Tables.
EDITOR'S NOTE. The Hazardous Ma-
tenali Tables are filed separately in Tab
Section 221. Insvuctions for use of the
Optional Table appear at the begumiag
of that table m Tab Secuon 221.
ttebpan C-Shlppm« »apaft
IITUOO ABpHcaMUn.
(a) Detention of Hazardous meitnals
ttQiund Except as otherwise provided
is thu subpan. each person who offen a
hazardous matenal for oaniponauon
«h«ii describe ate hazardous maienal on
the shipping papet in the manner required
by this subpan.
(b) This subpan does not apply to any
maienal. other than a hazardous waste
or a hazardous substance, that is—
145 FR 34560. May 22. 1980. effective
November 20.1980]
(I) An ORM-A. B. or C. unless it is
offered or intended tor tnmponauon by
air when it U subject to the regulations
pr^mmf to craasvonauaa by air as
apacined in 1171.101: or
C) Act ORM-A. B. or C. UBlau It la
•fend or Intended lor transportation
by nur when a is subject to (be n«u-
tetlou venaizuBg to transportation br
water as spectned in 1172.101: or
tg> AB ORM-D TXSUCSS it U offend or
intended for nnsponatioB by air.
(c) The requirement of f l72.20XaX3)
pertaining 10 the display of identification
numbers on shipping papen docs not
apply prior to July 1.1981.
(45 FR 34560. May 22. 1910. effective
November 20. 1980}
ta> Confeazi. Whan a daterlptlon of
t^y,^!— Bitentj tj lequirad t* be m-
•laded OB a atupptna; paper, thai de-
acnptioa mutt conform to tb* foDowtnc
111 When a baaardatu material and a
material not subject to the nqmnmesta
er tttit aubchaptar an davrlnerl OB the
same ablpptnc PaP*r. tb* bacardous ma-
tanal dascnpoon cBtncs nauind by
I17L202 and those additional saints that
may be required by 1172.203.
be enured after the hazard dats m
the basic description.
(b) Norn* e/dupptr. A shipping paper
for a shipment by water must contain the
game of the shipper.
IITUM Descripdva of taaardo-u an-
imal oa shipping papen.
(a) The thipping descnpuon of a
hazardous matenal on a shipping paper
musi include*
MS FR 34560. May 22. 1980. effective
November 20. I960; 45 FR 74640. No*.
10.1980. effective Nov. 20.1980|
(I) Tbe proper shipping name pre-
scribed far the material In 1172.101 or
1172.102 (when authorized):
US FR 34560. May 22, 1980. effective
November 20. 1980: 45 FR 74640. No*.
10.1910. effective Nov. 20.1980)
(2) Tbe hazard dats prescribed for the
material tn the same season. Except (or
• proper thipping name that eontatni
words describing more than one hazard
dass. inclusion of the hazard dats n not
required when the words of the proper
shipping name contain the key word or
words of ihe hazard cuss of the mate-
rial, such u Flammable liquid: Pooon B.
•UftEAU OF NATION*L AMAIM, INC.. WASHINGTON. DC JCCJ7
-------
HAZARDOUS MATERIALS TRANSPORTATION
UquiC. Radioactive device, or Corrosive
liquid.
(43 FR 34J60. Mav 22. 1980. effective
Novefflbe' 20. 1980 •».' FR 7*6*0. Nov
10. 1980. effecuve Nov 20. 19801
(3) The identification number (pre-
ceded by "UN" or "NA11 u appro-
priate) presented for the material in
the same section, ind
(45 FR 34560. Ma> 27. 1980. cffecuvc
July I. 1981. 45 FR 7*640. Nov 10,
1980. effecuve Nov. 20. 1910]
(4) Exctp: for empiv packaging!. UK
lotaJ quantity (bv weight, volume or as
otherwise appropnaiel of tht hazardous
material covered by the description
(b) Except u provided in Uui nibpan.
the btisic description specified in para-
graphs (aKt). (2) and (3) of ihu section
musi be shown in sequence For example-
"Cr«olme. Flammable liquid. UN 1203 "
(45 FK 34560. May 22. 1980. effective
November 20. 1980]
(c) The total quantity of Uie maiena!
covered by one descnption must appear
before or after, or both before and after.
(he bai.ic descnption required and autho-
rized by this subpan
(45 FR 34360. Ma> 12, 1980. effective
November 20. 1980]
(1) Abbreviations nuw be used to ipecf>
the type of packaging and weight or
volume For example- "40 cyl. Nitrogen.
Nonflammable gas, UN 1066. 800
pounds". "1 box Cement. liquid, n.o.s.,
Flammable liquid. NA 1133. 22 Ibs "
(4} FR 34J60. Miy 21 1980. effective
November 20. 1980)
(2) The type of packaging and destina-
tion marks may be entered in acy ap-
propriate manner before or after the
basic docnption.
(45 FR 34560. May 22. 1980. effecuve
November 20. 1980. 43 FR 74640. Nov.
10. 198i3. effective No*. 20. 1980]
(d) Technical and chemical group
name may be entered in parentheses
between the proper shipping name and
(45 FR 34560, May 22. 1980. effective
November 20. 1980]
I1TUOJ Addloowal esscrtprioa iwjnir*-
(a) Etrmpnow Each shipping paper
Bade under an cxcsBptm suit bear the
notation "DOT-E" followed by the ex-
cnpaoti number assigned and so located
thai the notation u dearly anonstrrf with
the tampuon to which the exemption
jgftifi
Q>)£iMA4rf fisBiu'MfS. The dtacriptioB
for o BBtcnal defined u "limited quaa-
tJries" IB ihu rubchapter aim mdudc the
words "Lontad Quantities" or "Ltd.
Ofy." following the bane description.
(c) ftaardma ntmaiua. (I) If the
proper shipping name for a mixture or
•glutton that u • hazardous rubnaace
does not idcnDfy the coniutuenu making
h a hazardous tubnance. the Dame or
oames of nice uardous substance COD-
sorueou. as shown m 1172.101 shall be
•sered ia tucoaoon with the bane
description. This requirement also ap-
plies »hen descnpuons from the Optional
Table in {172.102 are "ted
|45 FR 34560. Mav 22. 1980 effective
November 20. 1980. 45 FR **640 Nov
10. 1980. effective Nov 20. 1980)
' (2) The letters "RQ" shall be entered
on the snipping paper ether before or
after the basic descnption required by
{172.202 for each hazardous substance
(set definition in (171.8) For example
"RQ. Cresol. Corrosive maienai. NA
2076." or "Adipic acid. ORM-E, NA
9077, RQ "
(45 FR 34560. Ms> 22. 1980. effective
November 20. 1980]
(d> Radioactive mattnal (1) The
descnption for a shipment of radioactive
matenal must include the following addi-
tional entries as appropriate.
fi) The aame of each mdioauclide u
the radioactive mitenal thai u listed in
II73J90 of this subdiapur. Abbreviuoiu.
e.g . ""Mo" are authorized
(11) A descnption of the phyitcal and
chemical form of the material, if the ma-
terial is not in special form (generic chenu-
cal description is aconiable for chemical
form) 145 FR 34560. May 22. 1980.
effecuve November 20. 1980]
till) The actiiity erataiaid m each
imckafe of tbt shipment in lams of
eune miUlcurtes or nicncuries At>-
brevaoons are authorized. For the ship-
ment of packages containing large
quanurv radioactive materials (see
|l?3.389(b) of this subchapter). the words
"Large quantity" must be entered in
association with the basic descnption
146 FR 5298. Jan. 19. 1981. effective
Feb. 1.1982)
(IT) The eattvor? of label applied to*
each packaie ID ihe liura-iti. tvr exam-
ple- -RADIOACTIVE WHXTB-X.-
«*) The transport ado assumed to
each paek»ts in the aaipaeat beanni
KAPIOACrm TELLOW-n or RA-
DIOACTTVr TELLOW-m label*
ITU For a shipment of astilt radioac-
tive materials—
(A) The words "Finite Erempt.- If the
packate la exempt punuani to 117JJM
(a) of Hits tuhctiaptcr. or
(B) If not oenpt, tne assUs elsas of
nch mckatc in the :n -ment pniusnt
to linjiviaj of tab eubehapttr. cad
1C) For a Flattie Class m shipment.
Che additional stotmtten: "Wammj—Tta
afle Class m Shipment Do not Load
More T&an • • • Pmctatts par Vantcls.*
(Asiemu to be mlaeed br appropnau
naabtr.i "In loadlnf and Btormte Arau.
Keep at Lean M Vm (• lttun> tram
Otter PsMkaffts Btannc Rodioaetrn La-
fD) If a Fttdu aass m shipment to
to be (nnspencd by vmtar. tne supplt-
mantary tvatatsoa sntn also tncrudt the
teUovtnt itatement: Tor sbipaat br
water, only one Rsafle CUss m ship-
ment to permitted & each hold.*
of UUs sub-
enapter. tne anipplni paper snail be
aanotaud vu& the lollowiai entry-
Thu wupmmt eonmni Mekjwa of Ttw
A/lov specific inintr rMloaeuve tBauruai
Umiud tn MEOrdanc* wnh l&t im IAEA
lUfulttioiu puiwant to th* prwuioru of
«S CTR lliaaiel. (Krm«priHf»nu ootrr to
(c) Empty pedaling!
(I) Except for a tank car. or anv
packaging that still contains a hazardous
substance, the description on ihe shipping
paper for an empr> packaging containing
the residue of a hazardous material ms>
include the wordhl "EMPTY" or
"EMPTY Last contained ..... ai ap-
propnate in association with the basic
descnption of the hazardous material
Ian contained in the packaging
(4S FR 34560, Ma> 22. 1980. effective
November 20. 1980: 45 FR 74640. Nov
10. 1980. effective Nov. 20. 1980)
(2) For cmpry tank can. sot |l74iS(c).
ef this lubdiapter.
(45 FR 34360. May 22. I9M. effective
November 20. 1980]
(j) If a p^*^s*"g '•"•I"*"! i nnk car,
eomains a residue that u a hazardous sub-
stance. the descnption on the shipping
paper shall be prefaced «nth the phrase
"EMPTY. Last contained ..... and
shall have "RQ" entered before or after
ihe basic descnption.
[45 FR 34560. May 22. 1980. effective
November 20. 19801
(f) TiwtpoHOBO* by 4V. When V
paeksft containing s hazardous soate-
nal is offered for trantporunon bv air
and this tubcbapter prohibits m trans-
partition aboard passenitr-carryini air-
craft. the words "Cargo aircraft only"
must be entered after the basic descnp-
pen. However, until July 1. 1983. the
wards "Cargo-oruV siren ft" may be mfd
|4S FR 62079. September U. 1980. cffec-
ovcJulyl.198)]
(|) Trmtpenaaon fy rtl (1) The ship-
ping paper for a nil car containing a
nlT.-««... MtatensJ must contain the
'Ptacarded- foUowed by the
of the placard required for thi rsi
ear.
Qi Tne sMppai paper foe each tpcn-
AcarioB DOT I12A or I14A tank car
(without baad shields) eontainiag a
Dammsbk eompmsed fas must contain
the netanon. "DOT 112A" or "DOT
114A." as appropriate, and either "Mur
be handled in accordance with FRA E.O.
No. 5" or "$he*t to rest per E.O No. 5 "
ih) Tiwponatton by AI«ASMV. Pot.
lowing to* basic descnption for a bas-
sotfous matattal tn a tperlflration a
-------
COMMUNICATIONS
9938.2
215:0115
Quenched and tempered steel, there must
be entered for^
(1) AnAdvrouJ ammonia (11 The
words '0.2 per cent water" to mdlciie
tht luitabUJty for sojpsint autv/drous
ammonia in tht carte tank as author-
ised br 1177811 of this lubchapier. or
(ill The words "NOT TOR Q AND T
TAMES1' when the anhydrous ammonia
does not contain OJ per cent or more
water by weight.
(3) lintftta petroleum 001 Tht word
"Non-eomsltt" or 'Non-car" to indicate
tbt nuubility lor shipment of the -Non-
corrosive" liquefied petroleum pu of-
fered for transponauos BT cane tan*
u autbonsed by I iTSJlitatU) Note-
19 of tbls lubchapte.-
(U Tranrporiojiffn bv voter The number of each type of pack-
aft incJudlnr taost ID a Ireiant container
or on a pallet, and
till) Tna gross weight of each type of
package or tbt individual groat weight
of each package.
(2) The shipping paper for a hazardous
maienal offered for transportation by
vessel to any country outside the United
SUIB must hive in parentheso the techni-
cal name of (he matena.1 immediately fol-
lowing the proper shipping name when
the maicnij is describee: b> an n.o.i envy
in S171 101 or {172.102. For example
"Corrosive bauid. n.o.s (Caprylyl
chloride). UN 1760 " If the material u a
mixture of rwo or more hazardous ma-
icnals. the names of ai least two com-
ponent* mosi predominately contributing
to the hazard or hazards of the mixture
shall be enured ID parentheses. For exam-
ple. "Flammable liquid, corrosive, n.o.s.
(Methvi alcohol. Potassium hydroxide),
UN 2924 " The provisions of this para-
graph do aot apply if—
(43 FR 34360. May 22. 1980. effective
November 20.1980]
(f) Tht n.o.s. description for the
maienal (other than a mixture of hazard-
ous materials of different daises meeting
(he definition of more than one hazard
dais) contains the name of the chemical
dement or troup which u prunanJv
rerecnsbtt for the maienal bang induced
n we hazard dais radicated. For example-
"Mercun compound, soiid. n.o-i.. Pouon
B UN 2022 "
(4) FR 34S60, May 22. 1980. effective
November 20. 1980: 45 FR 74640. Nov.
10.1980. effective Nov. 20.19801
Oft The n.o-s. description for the
material (which u a mixture of hazardous
materials of different dasses meeting the
definition of more than one hazard dais)
contain) the name of the **-"""«| dement
« group responsible for the material meet-
tag the definition of one of these daises.
In such cue. only the technical name of
the component that u not appropriately
identified in the n.oj. description shall
be entered in parentheses. For example:
"Carbamaie pesticide, liquid, n.o.s.
(contains Xylene). Flammable liquid.
UN 1738."
Mftll
(45 FR i4J«. Ma> 22. 1980, efr«:ive
November 20. 1980. 45 FR 74640. Nov
10. 1980. effective Nov 20. I9S01
(in) To the identification of more than
one hazardous mitenaJ in a mixture
pnortoJu!> 1. 1981
[45 FR 74640, No«. 10. 1980, effective
Nov 20. 1980]
(3) The entry "Skin corrosive onlv"
must be induaed to also authorize "under
deck" stowage for corrosive liquid, n.OJ.
and corrosive solid, n.o s. thai met: onlv
the corrosive to skin cnteru of {173.240
(j) Sangf rous Wen Wts The words
Danieroui When Wet" shall be entered
on the snipping piper in association w>ih
the basic descnption when a package
covered b> ihe basic description is re-
quired to be labeled with a DANGEROUS
WHEN WET label.
(45 Fr 34560. Mav 22. 1980. effective
November 20, I9SO]
(I) This requirement does not apply
prior 10 JuJv t. 198 1
(45 re 74640. Nov 10. 1980. effective
Nov 20. 1980)
(k) Amorous manuals Notwithstand-
ing the dais to which a material u as-
signed—
(45 FR 34560. Mav 22. 1980. effective
November 20. 1980. unleu otherwise
nated ]
(1) If (he name af the compound or
principal constituent thai causes a ma-
terial 10 meet the definition of a poison
(according to thu subchapter) is noi in-
duded in the proper shipping name for the
material, the name of that compound or
constiiueni shall be entered on the ship-
ping paper in association with the shipping
description for the material The name of
tht compound or principal constiiueni
may be cither a technical name or any
name for the material that u listed in the
NIOSH Registry. Thu nibpanpaph does
not apply to—
(45 FR 34560. May S. 1980. effective
November 20. 1980. unleu otherwise
Rated. 45 FR 74640. Nov. 10. 1980. ef-
fective Nov. 20. 1980)
(!) A maienal having a proper shipping
name that includes the chemical dement
or group which causes the material to be
a poison.
(u) Limited Quantities.
(45 PR J4560. Mar 22. 1980. effective
November 20. 1980. unless otherwise
gated.)
(2) If • Bquid or solid material in a
package neeu the definition of • poison
according to thu rubehapter, and the
faa that n is a poison it not dudoted in
ike chipping name or dais entry, the
word "Poison" shall be entered on the
ttaippmi paper m association wnh the
chippini descripoon.
{45 FR 34560, May 23. 1980. effective
November 20. 1980. unless otherwise
stated: 45 FR 74640. Nov. 10. 1980. cf>
festive Nov. 20. 1980]
0) The provisions of paragraph* &XD
•nd (2) of thu *tcaon do DOI apply—
(I) To omiun"T commodities, ORM—
J4S FR 34563. May 22. 1910. effective
November 20. 19601
bv THE IUMAU Of NATIONAL AMAIMS INC WASHINGTON OC 10037
(u) To compounds or principal con-
stituents thai would cause death b> cor-
rosive destruction to tissue rather than b>
sysierruc poisoning
(ml Pnor to Jul> 1. 1981
[45 FR 34560. Ma> 22. 1980. effective
November 20,1980]
(I) IM peneblt tanks A hazardous
maienal described by an "n.o.s" entrv
in {172.101 or {172.102 (when authorized)
and offered for transportation in an IM
portable tank must be described on
shipping papers u accordance with the
provisions of paragraph- (iX2) of this
SKIIOR
(46 FR 9880. Jan. 29. 1981. effective
Mayl, 19811
1172.204 Shipping certification.
U) General Eicept as provided in
paragraphs (b) and (c) of this section.
each person who offers * hazardous ma-
terial for tnnsportanon shall cenifX that
the material offered for oansponanon »
in accordance with thu subchspter bj
printing (manual); or mechanicallO the
following statement en the shipping
paper containing the required shipping
dcscnpnoB.
• Ian t* M osrtzfr that tbt »bo«M*a*4
*rr pfopui* rti»m«l tmcna*.
. Burua ttc UMIM. taa tn IB
•iMlltinn Sir wtaipanaMn MCV«-
iac'to «ta ftppUASA* nsvuoeat of tt«*t-
S*fMut o» Ttuipenkiiaa.
NOTE.—In line •• ol UK o-i fiaiimi m em.
tneh ui of iha neon
•IT bt nionnuitd (or tta «oru
(45 FR 34560. Mav 2:. i9t(J, effective
November 20.1980]
(b) fzerpnow. (I) Except for a
hazardous wane, no certification u re-
quired for a hazardous material offered
for mnsponauon by motor vehicle and
transported ~*
(45 FR 34560. May 22, 1980. effective
November 20.198%
U) In a oaifo Cask nippUed «r U>e
CU> Br ttot abtppcr ai a private ourl-
•r except tor m aazaxoau* maunaJ
(bat u to be imolpped or tnaaterred
tram on* carter to another.
(2) Ko ontlfieaxlon la iwouired for
the return of an enztty ttzut ear which
prvtloualy ooatajned a bacardout naa-
tenaJ and wnlcb. baa not been eleaoed
__ •
rrofuportattpn bv etr—(1)
on urmtaining the f allow-
tn> lazunian mar be wed ID Blaoa ef (be
oaruncitioB required or g*racraph ta>
c/ taiajecttoai
I hepwr emifl V»t MM eeaMBti at ttkt
an Ml* and Mcunuir •»•
«be«i wi piopef aavvint
azreraft epaimiM for tfmnaponauon by
an ahaD profUU two OVDM of
BgiiCiMlOB
1 178 JO o
_ __
178 JO of tab aabchapter.)
tl ) Peuenftr axd earoo
panon who effen (or Bmaiporutien br
Mr a hanrtnni matertal authonutf lor
•If ttuuporiaonn abaU add to u*^ ear*
idea raejmred to thu aeexton tn* loJ.
-------
215:0116
HAZARDOUS MATERIALS TRANSPORTATION
ihlpBut u vithla tbi Umiutlou
pmer.BM tor puuen' urenn/euio-eaiT
•ircnri totliu aouppllttblx
(4) Rodioccuvt material Each ptnon
who alien any radioactive material for
trmiuporutien ibeani i passenger-
carrying aircraft ihall sign
(mechiinically or muiually) a printed
etmTicata auting that the ahipmini
contains radioeetivt msienal intended
lor uic in. or madent to. reieerch.
medicij dlagnoin or treatment. Pnor to
May 3.1961, thii provuioo doci not
•pply 10 matenala meeting the
rtquirtmtnu of i 1/3J71 (a), fb!. or (c)
of thu subchapter ic effect oo MayJ. 1079.
Slfnetvrt The earttflettuni r*-
qtartd by pancraph (a) or of fen
(1) Must ba taflbly Ufaad by a prin-
cipal, cimeer. partner, or employee of U>«
UJppe- or his aycet • tad
(2) 'May be Itf-fcly suaed —"—"f
by typewriter, or by otter mnrhanin>l
Hartrdoui waste manifest.
(43 FR 34360. May 21. 1980, effective
November 20. 1980]
(a) No penon nav offer, tnnspon.
tmufe.'. or deliver a hazardous wane
(waste) unless * hazardous waste man-
fer. (mijufat) u prepared. signed, earned.
and pven as required of thai penon by
this iceuon.
(b) The shipper (|enerator) shall pre-
pare th: manifest in accordance with 40
CFRP«n262
(c) The ongjBal copy of the manifest
must b>! dated oy. and bear the hand-
written sifnature of. the person rcprcscni-
m|-
(1) The shipper (generator) of the waste
at the nme » u offeree for transportation.
and
(2) The iniuaJ earner accepting the
wane for transporuuon
(d) A copy of the manifest must be
dated tot. and bear the handwritten dena-
ture of the penon representing—
(I) tieb subiequeat earner accepting
toe vatte for transportation, at the one
of acceptance, and
(2) The designated facility receiving the
waste, upon receipt
(c) A copy of the manifest bearing all
Kjquirad dates and signature must be—
(I) Given to a penon representing each
came accepting the wane for transporta-
tion.
(21 Gimed dimng transportation in
the turn manner as required by this sub-
cnapur for shipping papers.
(3) Given 10 a penon representing the
designated facility receiving the wane.
(4) Rimmed to the shipper (generator)
by the earner that transported the waste
from the United States u a foragn derana-
oon with a Dotation of the date of de-
parture from the United States, and
(5) Ruamed by the shipper (generator)
and by the nunaJ and each subsequent
earner for three yean from the date the
waste wiu accepted by the initial earner.
Each reuined copy must bear all required
•gnatuns and dates up to and
those enured b> the next penon who re-
ceived the waste
(f) The requirement* of paragraphs (d)
and (e) of mis section do not applt to a
rail earner when «aste is delivered to i
designated facility by railroad if—
(1) All of the information required to
be enured on the manifest (except genera-
tor and earner identification numoers
and the generator's cernficauon) is entered
on the shipping paper earned in accordance
with {l"4.26(ci of thu subchapier.
(2) The delivering rail earner obtains
and retains a receipt for the waste that
u dated b> and bean the handwritten sig-
nature of the penon representing the
designated facility; and
(3) A copy of the shipping paper is
retained for three yean by each railroad
transporting the waste
(I) Tlie penon delivering a hazardous
waste to in initial ml earner shall send
a copy of the manifest, dated and signed
by a representative of the rail earner, to
the penon representing the designated
facu»>
(h) A hazardous waste manifest required
by 40 CFR Pan 262. containing all of the
information required by this subpan.
may be used as tne shipping paper required
by this subpan.
Subpan 0—Marking
1172.300 Applicability.
(45 FR 74640. Nov. 10. 1910. effective
No*. 20. 1980]
(a) Each person who offers a haz-
ardous material for transportation shall
mark each package, fraght container.
and transport vehicle containing the
haurdoui material in the manner re-
quired by thu subpan
(b) When assigned the function by
thu subpan. each earner that transports
a hazardous material shall mark each
package, freight container, and transport
vehicle containing the hazardous mate-
rial in the manner required by this
subpan.
General marking rtqalremcnu.
[43 FR 34360. May 22. 1980. effective
November 20. 1980. unless otherwise
sated, redesignaied u 43 FR 74640.
Nov. 10. 1980. effective Nov. 20.1980]
(t) Except as provided by this tub-
chapter, each penon who offers for
transportation a hazardous material m a
packaging having a rated capacity of 110
gallons or less shall mark me package
with the proper shipping name and
identification number (preceded by
-UN" or "NA" at appropriate) assigned
to ihe material in 1172.101 or 1172,102
(when authorized).
(43 FR 74640. Nov. 10. 1980. effective
Nov. 20. 1980]
(I) The proper shipping name is not
required to include the word "Want" as
fpcafied by (172.101(0(10) if the
package bean the EPA marking pre-
scribed by 40 CFR 2C2J2.
(43 FR 74640. Nov. 10. 1980. effective
Nov. 20.1980]
(b) When n hat been determined by
Chomicai Regulation Reporter
ihe shipper that a package has been
previously marked as required for the
maienaJ it contains, u need not be
remarked. (For emptv packagmgs. see
{173.29 of thii subchapier )
(c) This seciion does not apply to—
(I) Oisp!a> of identification numbers
of packages containing Limned
Quantities (see {171.8 of this sub-
chapter) or materials classed as ORM-D
(see {173.1200 of thu subchtpier) when
packed with no other hazardous maim*
(43 FR 74640. Nov 10. 1980. effecive
Nov. 20. 1980]
(2) Displav of identification numbers
on paekagmgs having a rating capicus
of 1 10 gallons or less filled for shipment
prior to July 1. 1983
(43 FR 74640. Nov. 10. 1980. effective
Nov 20. 1980]
(3) DispU) of new or changed proper
shipping names for hazardous materials
adopted under Amendment No 172-38
on packages filled for shipment prior to
July 1. 1981
(43 FR 74640, Nov. 10. 1980. effective
Nov 20. 1980]
Note —EPA requires speaal marking! for
baaardoui waste See 40 CFR J« 12
(43 FR 74640. Nov 10. 1980. effective
Nov. 20. 1980]
II72J02 Export shipments bv water.
(a) Each package of hazardous mate-
rial offered for export b> water and
descnbed by a "n.oj " entry in (172.10!
or |172.I02 (when authorized) must
have the technical name or names of thr
material added in parentheses immedi-
ately following the proper shipping name
(sec {172^03(iK2)). For exampie Cor-
rosive liquid, n.o.s. (Caprylyl chloride)
(43 FR 74640. Nov. 10. 1980. effective
Nov. 20. 1980]
(b) For a mixture of two or more
hazardous materials, the technical name
of at least two components most pre-
dominately contributing to the hazard
or hazards of the mature must be added
m parentheses immediately following
the proper shipping name.
143 FR 74640. Nov. 10. 1980. effective
Nov. 20. 1980]
(e) The requirements of thu section to
identify more than one hazardous mate-
rial in a mixture do not apply pnor to
July 1. 1911.
(43 FR 74640. Nov. 10. 1980. effective
Nov. 20. 1980]
1 172J04 Marking tiqalraemia.
(a> Tba marklni required m tola tub.
pan— (D Mot be durable, to BniUsh
and printed on or amud to Ihe ewia«e
of a. mrtite or on a label, tat. or aim,
etf anarffty
(8) afon be mwbanzred by sabeli or
(4) Kan 'be located away tram any
other tnariant ceneh aa atfv»raalni) mat
exmld autonanoaUy reduce tu affecuv*-
ilTUOft CeealgiiM's or Coatlgaor's
(a) Each package containing a hai-
-------
COMMUNICATIONS
21S:01t7
ardoui miiensl offend for iraniporu
non must M marked »ith (he ntmt ind
address of the connrnrt or consignor
cietpt «hen the psektge u— U) Trim
ported bv high»iv and ml! noi be trans-
ferred from one motor earner 10 Mother
C> Pmn of a eutead lot. truekloBd lot.
or trclrbt eanutaer load, aed tbr enure
oontcau o: the raj] a.' crack or trticnt
container are tendered tram OM eon*
•l&or to one ooxui(&M. or
(3) A portable tank, earn tank or
tank car.
f I72J08 Authorised abbrrvttttoiu.
U) Aboreviaiicns mi> not be used in
I prope- ihippmi name marking except
in the following instances—
(45 FR '*640. Nov 10. 1980. effective
Nov. 20. 1910)
(I) For marking descriptions of am-
munition. such as Ammunition for
cannon without projectile. eie.. the
words "with" or "wiinou:" maj be
abbreviated at "W or "W/0" For
example "Ammunition for cannon w/0
projectile "
(45 FR 74640. Nov. 10. 1980. effective
Nov 20. 1980]
(I) The abbreviation "ORM" ma> be
used in place of the words "Other
Regulated Matenal "
f45 FR 74640. Nov 10. 1980. effective
Nov 20. 1980)
flTUIO fUdiMOfrt auteriaU
(t) la addittoB to any other martlnm
mured by Uui subpan. eaca package
ftf^»f tnifif radioactive matanalf suit be-
marked u follows: (1> Each package of
raOloaefltt Batarlab to exeau of 110
pouacj Off Ulorraai) autt have iu
frost weicnt plainly and durably marked
OB tbe euoide at the packace.
(2) »>r pmeJcMc ot radioactive mate-
rtalf which conforms
ferTypeAoiTyvcBpaekattecfll ITS-
U»(J) and tad ITUtaibi and (c)
of this rabchapter) rauit be plainly and
durably marked on tht outaidi of Ibe
pa«kMt IB ltnen at tout H-IBCB (IS
•a-iAttb with the trordf TXPC A" or
•ITM, B" ai appropn*M A packacmt
waict U not la eompUaaee wtc t&oe
.«qulreaenu may not be eo marked.
• (I> Xaeb pe«kate of rmdJo»ea»« mate-
rial defaced for export ablpmtnt mutt
•Ho Be marked "USA" in conjunction
with the ipeafietuOD marktoi, or other
packafe certificate identification. (See
li 173.3931 and HJ.SHo of Uuiiubehan-
icr.)
Uqold Raardou Mtterkb
(•) Except u provided in this xenon,
each package havun an uuide perlnpni
liquid huvdoui aeienab
(45 FR 13087. Febnui; 28. 1980. etheme
September 1. 1980)
(1) Packed *Rh etaum upward, and
rti Ucibly marked "IHia SIDE tTP"
or "TBIS END OP" ai wprepriau. to
loOloHf i&e opvkrd pecmon of tae m-
•de packa«i&|.
(6> Cweet ai eUiervbt prescribed te
Part 571 ef this nibchapier criinderi of
Uerueicd coBprwied fai and tpec'Jlea*
Uon containers SO. 1711. J7P. and SIP
ant net reeuired to b* marked. THIS
BIDE OP" or TBIS OS OP '
to Arrowi for purpotei otter Jbanln-
dicaunc proper package oneeuaon may
not be displayed BO a pe,eka<* eoBtmln-
inr » bacardeua mattrtal that ti a Uauld
(li An arrow irabol lnd;caunc Tnli
«a> Dp" u iped&ed la ANSI list il»H
entitled "Pictorial alartuu lor HaaoUlni
ef Oeods" tneuld b* used Us addiaon «o
tb* marUnr rtcalrtd by into »e«een ead
117:^J ot tan nbchapter
(dl Except when offered for trampor-
tiuon bv air, packages corr.iminj flam-
ruble liquids in iruide packtginei of one
quan or Ins prepared in accordance with
»PJ Il8i») or l73.!200iaKI) of ihii
subchapir are cxcepted from the reoviire-
menu of paragraph
ur. package containing flarrjnible bquicti
in iniide packaging of one quan or lett
prepared in accordance with i{I73.M8(a)
or 17] I200TIMI1 Of thu wbchapte- are
excepted from the requiremenu of para-
graph (a) of this section when packed
witr luffiden: absorption mitena! between
the inner and outer packaging! to com-
ptetelN absorb the liquid contents
(45 FR 13087. rtnruary 28. 1980. effec-
tive immediaiel)-: 45 FR 68653 October
16. 1980. effective November 17.1980)
(172JU Packaging eoaiaiiuog naienal
daneduORM.
(a) Eacn packapagi having a rued
capacity of 110 gallons or lesi and con-
taining a material datscd ai ORM-A. B.
C. D. or E muii be plainly, durably.
and lepbly marked on at leait one tide
or end with die appropriate ORM
designation mmediaicly following or
below the proper shipping name of the
maienal. The appropriate ORM designa-
tion muii be placed witnin a rectangle
that u approximately W inch (6.3 mm.)
larger on each side inae the designation
The appropriate dcaifnauon for each
ORM must be:
14! FR J4560. May 22. 1980, effective
November 20. 1980. 45 FR 74640. Nov.
10.1910. effective Nov. 20.1910)
0) ORM-A for an ORM-A.
(2) om-a-nv OUT tor u
OlUi-B thu to • Mild tfld to oowoSft
OBI, to alunUBua when vet
ui «3B*&B for an, OKM-S other tbaa
that described. A pancraph u,t (» of
<«) oiuue for u cnuc-c.
(t) mot-O-AIR for aa i
to prepared for BIT ehlpment tad
Mid b ueoraaaet sntb the
ot 117J.» of thu tubchapier.
«•> OlUC-Ofor aaORM-C other CJaaa
that deatrtned IB panmnh <•>(•) of
t&u acction.
C7) ORM-E for u ORM-E.
(45 FR J4J60, May 22. 1980. effective
November 20. 1980)
(b) When the ORM-0 marking in-
cluding the proper shipping name can not
be affixed on the package surface, it nuv
be on an attached tag
|c) The marking ORM-A. B. C. D. or
E u the eeruficanon by the person offering
the package for transportation that the
material u properly described, daiied.
packaged, marked and labeled (when
appropriate) and in proper condition for
irutponation according 10 the appli-
cable regulations of thu subchapter This
form of certification does noi preclude
the requirement for i certificate on a
shipping paper when required by Sub-
pan C of this Pan
(45 FR 34360. May 22. 1980. effective
November 20. 1980. 45 FR 74640. No*
10. 1980. effective Nov. 20. 1980)
I17U24 Haardou sabsianres.
(43 FR 34340. May 22. 1980. effective
Nov. 20. 1980. unicsi otherwise stated.
heading amended at 45 FR 74640. No>
10. 1980. effective Nov. 20. 1980]
U) If the proper shipping name for a
mixture or solution that is a hazardous
substance does not identify the con-
tniuenu making it a hazardous tub-
nance. the name or names of such
hazardous substance constituents as
shown in 1172.101 shall be entered in
auocution with the proper shipping
name on each packaging hiving a
capacity of 110 gallons or leu This
requirement also applies when descrip-
tions from the Optional Table in
1172.102 are used.
(45 FR 74640. Nov. 10. 1980. effective
Nov. 20. 1980]
(b) The tetters RQ snail be displayed
at association with the proper shipping
ame OB a packaging having s capacity
Of 110 gallons ot leu that contains a
hazardous substance.
(43 FR 74640. Nov. 10. 1980. effective
Nov. 20. 1910)
(c) Thu section does not apply pnor
to July 1. 1983.
(45 FR 74640. Nov. 10. 1980. effective
Nov. 20, 1980)
Portable inks.
(a) No person may offer for tnntpor-
tuion or transport a portable tank con-
taining a hazardous material unless u is
legibly marked witnn Jeiien or numerals.
BS required, measuring no leu than two
inches (50.8 mm.) in height—
(43 FR 14560. May 22, 1980. ctTccnve
November 20. 1980)
(I) On c*o opposing add with the
proper shipping name of the material.
md
(43 FR 34360. May 22. 1980. effective
November 20. 19801
0) As BTBOtbed by I172J32. wfch
the ricntincanon number specified for
Ihe material to 1172.101 or 1172.102
(vbcn nthomcdK «vtd
|45 FR 14360. May 22. 1980. effective
November 20. 1980: 43 FR 74640. Nov.
10. 1980. effective Nov. 20. 1980]
(i) On each side and each end. if the
1.3M1
*«<.«nM e» TXf limtAU Of NATIOMAI. A*«AI*S IMC. WABNIN6TON. O.t BOr
-------
215:0118
HAZARDOUS MATERIALS TRANSPORTATION
tank tiu a capaar) of 1.000 gallons or
more or
(45 FT. 34560. Mav 23. 19BC. effective
November 20. 1980]
(u) On two opposing fides ID assocu-
uon with the proper shippini name if ihe
tank his t capacity of leu than 1.000
gallons
|4i HI 34560. May 2J. 1980. effective
November 20. 1980. 45 FR 1*6*0. No*
10. 198:. effective No* 20. 1980]
(b) A portable tank marked wuh the
name or identification number of a
hazardous material ma> noi be used to
tnuispon anv other maienal unJesi (he
markuiu u removed, or changed 10 iden-
ufy the hazardoui matenal in lie port-
able tank, whichever u appropriate
|45 FR 34560. May 22, 1910. effective
November 20. 1980]
(c) The name of the owner, or when
appropriate, of (he lessee, must be lep-
My displayed on a portable tank thai
contain] a hazardous maienal
(d) If the marking required by sub-
paragraph UH2) of thn section u not
visible, a transport vehicle, or freight
container used to transport a portable
ttnk must be marked on each nde and
each end u required by (172.332 with
the identification number specified tor
Ibt mattnal in 1)72.101 or (172.10:
(wnen authorized)
(45 Fit 34360. Ma« 22. 1980. effective
Novembw 20. 1980. 43 FR 74640, Nov.
10, 1980. effective Nov 20. 1980]
(e) Each portable tank marked as re-
quired bv paragraph (a) of this tecuon
nun rtaair. marked unless u is—
|45 FR M560. Ma> 22. 19(0. cffecuve
NovcmbiT 20. 1980)
(I) TiUed with a maienal not subject
to tins subehamer: or
(45 FR 314560. May 22. 1980. effective
November 20.1980}
(2) Sufficiently cleaned of residue aad
purged of vapor to remove any potential
hazard
(45 FR 34560. May 22. 1980. effective
November 20.1980]
1172.328 Carte tanks.
(i) Except as provided ID this ubpan.
BO person may offer for transportation
or transport a hazardoui matenal IB a
cargo tan) unless the cargo tank it marked
as required by 1172.332 on each side and
each end with the identification number
ipeciTuid ilor the maienal IB 1171.101 or
(172.102 (when authorised)
U5 FR MMO. May 22, 1980. effective
November 20. 1980; 45 FR 74640. Nov.
10.198C. itneeovc Nov. 20.1910)
(1) A penon who offers a motor
came t hazardous material for trans-
ponaoon ID • cargo tank thaU provide
the motor earner tbe required tdeniifica-
Hen ambers OB placards or shall a/fa
eruft piinels containing the required
identification numbers, pnor to or at the
am* tbe material u offered for trans-
portation unless the cargo tank is already
marked wob the tdcnuTieauoB Dumber
required by this subpan in accordance
with paragraph (0 of (his section and
(173 29tcl of this lubchapier
|4! FR 34560. Ma; 22. 1980. effective
Nov 20. 1980. 45 'FR 74640. Nov 10.
1980. effective Nov 20. 1980]
(2) A penon who off en a cargo tank
containing a hazardous matenaJ for trans-
portation shall affix ihe required identifi-
cation numbers on panels or placards pnor
10 or at (he time (he cargo tank is offered
for transportation unless it u already
market! with identification numbci a>
required by (his subpan
(45 FR 34560. Ma> 22. 1980. effective
November 20. 1980)
(b) When the name of i material is
required b* thu lubchipter 10 be
rnancec! on a cargo tank, it must be
legib'v displayed on each end and each
aide in lettering no less than two inches
(SO.! mm ) in height
[45 FR 34560. May 22. 1980. effective
Nov 20. 1980: 4S FR 74640, Nov. 10.
1980. effective Nov 20. 1980)
(c) Rtqutrtt markings Gats Each
cargo tan* transporting flammable or
nonflammable compressed gas subject to
this lubchapter nun be markec as speci-
fied in this Pan on each end and each
side with-
it) The proper shipping name of the
(as. or
(2) An appropriate common namf for
the matenal such as "Refrigerant Gas "
(d) QT/NQTmarlcuijforMC330an4
MC 331 cvjo tanks Each specification
MC 330 and MC 331 cargo tank must be
appropnaiely narked "QT" or "NQT"
10 indicate it ii constructed of quenched
and tempered Reel (QT) or other than
quenched and tempered steel (NQT).
These markup must be placed near the
specification identification plate in lenen
BO less than two inches (50.8 mm.) in
ho grit
(43 FR 14640. Nov. 10. 1980. effective
Nov. 20.1980]
(e) A cargo tank marked with the
came or idenafiaoon number of a hazard-
ous matenal may not be used to transport
any other material unless the marking is
removed, or changed to identify the
hazardous material in the cargo tank,
whichever B appropriate.
(45 FR 34560. Miy 22. 1980. effective
November 20.1980)
(f) A cargo uuk that is required to be
marked with the name or identification
camber of a hazardous matenal must
main marked when empty unless it a—
(45 FR 34S60, May 22. 1980. effective
November 30.1980)
(1) Reloaded whh a material flat WBjea
10 thu fubchftptcn or
MS FR 3*560. May 22, 1980. effective
November 20.1980]
Q) Sufficiently cleaned of residue and
pursed of vapor to remove any potential
(45 FR 34560. May 22, 1980. effective
November 20.1980]
Chemical Regulation Reporter
(171.330 Teak can end nalu-vntt tank
car tanks.
(«5 FR 3456Q. Mav 22. 1980. effective
Not ember 20. I9SC. unless otherwise
stated)
(a) No person may offer for transpor-
tation or transport i hazardous material
in a tank car tothe* than « multi-urui tank
car tank) unless the tank car is—
(I) Marked on each side, when re-
quired b> Pan 173 or 179 of thu sub-
chapter, with the—
d) Proper shipping name of the ma-
terial, or
(L> Common name authorised in Aits
subcnaptet (or the matenal such as
"Refrigerant Gas "
(1) Marked on each side and each end.
as required by {172 332. with the identifi-
cation number specified for the matenal
in 1172.101 or {172.102 (when autho-
rized)
(45 FR 14640. No* 10. 1980. effective
Nov. 20.1980}
(b) The tellers in the marking of a
proper shipping name or common nimr
must be 4 inches (101.6 mm.) or more in
height wiin ai least a 5/8 inch (1! 9 mm )
stroke The separation between each
letter must be at least Vi inch (19 0 mm )
(c) No penon may offer for transpor-
tation or transport a hazardous maienal
in a multi-unit tank car tank unless n is
marked on opposing sides, in Inters and
numerals no less than two inche* high.
with the—
(1) Proper shipping name specified for
the matenaJ in ||72.101 or {172.102
(when authorized), or common name
authorized for the maienal in this sub-
chapter, and
K 74*40. Nov. 10.1980. effective Nov.
1980]
(21 Identification number specified for
Die maienal in {172.101 or {172.102.
(d) A. tank car or a multi-unit tank car
tank marked with the identification num-
ber or name of a hazardous matmal mav
not be used to transport any other matenal
unless the marking is removed, or changed
to identify the hazardous maienal that
the tank car or multi-unit tank car con-
tains, whichever b appropriate.
(e) A motor vehicle or rail car used to
Dampen a mulu-unit tank ear tank must
be marked on each side and each end. as
required by {172.332. with (he identifica-
tion number specified for the matenal in
(in. 101 or (172.102 (when authorized)
(45 FR 74640. Nov. 10. 1980. effective
Nov. 20.1980]
(f) If a mum-writ tank ear tank contains
ehtonnv mutant of the name "Chlorine"
is oot requiredI when the CHLORINE
label is «scd u provided m |lT2.40S(b).
(B) Each multi-unit tank car tank and
each tank ear (except when h contains a
eombuniMc liquid) mutt remaia marked
when empty unless—
M FR 74640. Nov. 10. 1980. effective
Nov. 20.1980)
(I) Reloaded with a material not sub-
ject to this cubchapter. or
-------
COMMUNICATIONS
9938-2
315:0119
(45 FR 146*3. Nov. 10. 1980. effective
No>. 10. I9SO)
(21 Sufficiently cleanei af residue trtd
pur|e4J*0. M»y 22- ISSO. effective
November 20. 1980; 45 FR "46JO. Nov
10. 1980. effective Nov. 20, I9&OJ
IS to inches <40
em.) wide with a 9/16 inch (11 mm.)
blick outer border. The identification
numbei shall be displayed in 4-mch (10
en.) black Helvetica Medium numerals
on the orange panel. Measurements may
vvy from those specified plus or minus
0.2 of w in:h (5 mm).
(2) The orange panel may be nude of
any durable mairna. prescribed for
placards in {172.119. we thai! be of the
orarig: color specified for labeis or
placards in Appendix A. to this Par..
0) The nunc and hazard class of a
materiiJ nprcMmed by the identification
Bum be:- roay be shewn m the upper led
border of toe oruge pane! in tetters not
note than '/• inch (18 poinu) high.
<*t Kxcepi for fixe and color, the
orange panel and identification numbers
ihaJJ be as illustrated for Uquefied
Detroitwn |ti:
materiaJ shall be diipiavtfi in the lower
corner of each placard u specified in
075
the person offering materiaJ for transpor-
tation in the cargo tank;.
(D If a placard is required by J I :;.»=.
an identification number may net be
displayed on an orange pane! unless it
is displayed in proximity to the placard.
{1T:JJ« IdenUfKitfon numbers:
provisions aad exceptions.
(45 FR J4J60, M*y U. I9W. effective
Nov. 20, 1980; 45 FR 746JO, Nov. 1C.
1980. effective Nov. JO. 1980|
(a) When not required or prohibited
by this lubpart, identification numbers
may be displayed on a iranspon vehicle
or a frtight container in the manner
prescribed by this subpan.
(b) For hazardous material: in hazard
classes for which placards are not re-
Quired. identification number) may be
displayed on a plain white squire-on-
point configuration having the same out-
tide dimensions as those prescribed by
this Part for placards. An identification
number displayed as authorized by this
paragraph is not considered a placard.
U) The 4-jnch (10 cm.) by 8'/: inch
(21.5 cm.) area containing the identifica-
tion number shall be located as pre-
tcribed by il?2.332(cX2) and .
(4) For different liquid disuUaM fab.
kochiding gasoline, in a comparuneiuea
cmrjo tank or tank car. If the identifica-
tion number is displayed for the distillate
fuel having the to«e»t (lath point.
(f| For each of the different liquid
diniUatt fuels, including gasoline, trtos*
poned in a cargo auk. ii the idtniiria-
oon Buraber displayed it for the liquid
distillate fuel having Uu lowest flash
point.
V4M1
Fftbluhcd br THE
W KATIOKAL ATP*I», WC-. t*fHWC1O|f. B.C. IOOJT
-------
215:0120
HAZARDOUS MATERIALS TRANSPORTATION
(61 On nurse tanks meeting in*
provisions or Sn33lS(m) of inn tub-
chapif
(71 On mulii-unn tank ear tanks prior
10 JuU I. 19S3
(B) On orange panels or placards pnor
to November 1. 1981
I172.J.IS Replacement of identification
nvrabers
J45 F* 34560. May 22. 1980. effective
November 20. 1980. 45 FR '*«J0. Nov
10. 1980. effective Nov. 20. 1980]
If more than one of the identification
numbc: markings on the placards or
orange panels thai arc required to be
duplivri ate lost 01 destroved during
irmnipenanon. the carrier shall replace
all ihe mining identification numbensi
as toon as practicable However, in
rich i case, the numerals ma> be
entered tejiblv b> hand using an in-
delible marking material This section
docs pieclude required compliance with
ihr placarding requirements of (his sub-
Chapter
Subpart E-Labeling
1171.401) C*aermJ labeling requirements.
Nui ovarpacked. and
•IIP Durably and Irftblr manra u>
•lecoraaiice with CCA Pamphlet C-~
APPC114U A
• 3> MUlurv ammunition thiopcd bv
for. or u ibe TJ-S Deponmeat of De-
feme (DOD) when in freight container-
load, amend or mickloai thipmenu. if
loaded and unloaded by the shipper, or
DOD
(45 FR !U5tO. May 22. 1980. effective
Nevembtr 20. 1980]
•4i PibCkace *M"*'»t''f a bacuiMwa
mauriPl other teas acomunltwa mat
to—in Loadtd tad unloaded under uir
mtrvtiton of DOD panoaaeL and
Eiicorud br DOD penoaaal m •
afparau vehicle
(B> Cnmprewad sai crlladar
aanur aouoMd to or OB a i
Mel*.
<6) Portable tank which u placarded
to accerchincc with § 171.514
(7) fretcbi eaotalner ba*inr a volume
Of MO cubic ftet or were which la ayb-
Jtn to 0 .172.SU:
(8) Package containing a maienai
classed as ORM-V B. C. 0. or E if that
package does noi comair. tn\ oiner ma-
tenaj classed at a haiaraous matenal
i hit requires labeling
1*5 FR 'ttftd. Vov 10. I9SO. effective
So> 20 1980]
(9) Package coroirung a combustible
bquic! sr
1101 Paeltat* e! low tptufte activity
radioacUte material -when being tnru-
ported la a trans Don vehicle assigned for
the aoie IMC ol the ceuignor under
1173.392 of this tubchapter
(IP Carte tank er tut car other
than a multi-unit tank car unit
>c> Prert'ions of rarvrraph A material ctMiei at O»iluei
Flanunable aolid or Flammasit hauid
that also meets trie oerlrii.or. of a Ponor.
B musi be labeled POISON in addition to
the clau labe.
141 A owwrtal claued at a Flunmiblt
aalid thai alfe meeu uie definitieo or a
«ater reactue mi'.eru) mu:t have both
thi rLAMMABLE SOUS and DAKGCR-
OLS WHEN WET labels affixed
' w*B* »'
anot ('
at— I
{172.401 Prohibited labeling
(a> Except ai provided ID paracnphi
ic> aad id: of Uiu aecuor. ao person
mi? offer for tnniportatisr. aad ae ear
ner aa> truupon anr package beanai
a label specified ta this aubpan uaii
O > Thi package conuini a material lhat
ls a hararooiu material ane
'2> The Ubcl npmtati a aaard of
tne baaardoiu maienai ua UM package.
ibi No ptnon may offer tot transpor-
tation aad as earner ma; transport a
package bearing any marbng or label
whien bv m eoler design, or shape nuld
be eaaf used with or conflict with a label
prescribed by tail part
ic' Tae restriction! in aanirapru
and «bi of thj aeetiOB de not applj
to packages labeled in conlormanee with
—M> Any United Nation* rteotrunenoa-
ttoa. including thi clan number A paekart eoniaintu a aampie of
a aasartou* material other toaa as ex*
plant*, mwit be ktMltd IB
with 1 172.«2(h).
| 172.402
(a> JfitrtpIe label!*? Eaeh paekaft
enatalalnc a eaaurtal meeting the ataal*
ttoa of man taaa eae haaud data mart
be tobtled u follow: (1) A maunal
rliasil M aa balod't A, Polaoa A. er
Raaioanive material that alao meets the
deriniuon of another hurt dan, mun
be labeled as required for each daw.
(2) A POUOB B uquia taat ai*o me:u
me Htf""""* of a n*~* •""'* liquid mutt
Charnieii rUguurton Keoonor
i!) \ mate-ial cussed as a
maienai thai aiso meets the definition of
a Poison B shall be labeled with a POISO*
label m addition 10 me class label This
Mbparagraph does not apol* 10 a maie-ial
thai would cause death due to eorrou»e
destruction 01 tissue rather than bv s>s-
lemic poisoning
(45 FR 34560. Mav 22. 1980. effective
Jul% I. 1983]
16) A matenal classed as • Poison B
Ihai also meets the definition of a cor-
rosive material shall be labeled with a
CORROSIVE label in addition to the
class label
(4! FR J4J60. Ma> 22. 1980. effective
Jul> I. 1983]
(7) A rrtaientl classed u a Flammable
liquid thai also meets the definition of a
Corrosive material shall be labeled with
a CORROSIVE label m iddmon to ihe
class label
[45 FR 34560. May 22. 1980. effective
ul> 1.1983]
(8) A matenal classed u a Flammable
wlid that also metis the definition of a
Corrosive material shall be labeled with
a CORROSIVE label m addition 10 the
dass label
(45 FR 345«, Mi> 22. 1980. effective
Jul> 1.1983)
(9) A maienai dassed ai an Oxidner
that also meeu the definition of a Cor-
rosive maienai shall be labeled *un a
CORROSIVE libel in addition to ihe
dass libel
(45 FR 34J60. Ma> 22. 1980. effective
July I. 1983]
(101 The rcouirtmenu of wbpineraphs
(5) through <9i of this paragraph do not
appK pnorio Jut) I. 1983
(45 FR 34560. Mi; 21. 1980. effective
November 20. 1*80)
tbi CAJtco A/ACJurr QNLT label
lacb penoa wae oflars for uaaipona-
tion br air a paakaie ooataiauuj a aas-
ardqui material aataoncad only on
eano aircraft anall ami to the eackaee
a CAKOO Aatciurr ONLY laaai vatca
!• deacribod IB 1172.448
ie> OAJfGXXOUS WHXN WIT label
lach penoa who aBen lor matpana-
Men a package aaatalatni a aaavdous
maunal must afta to the pacaate a
OANOOIOC8 WKXK «ZT label ai de-
•eruMd IB 1119.123 •aoa-nquina by
117U01.
(dl XAONSTIZXO HATtKlAL label
Sach penoa who affan for tnaapona-
•MB br air a paeaace meeuat tbe danni-
Uon af a ITT******^ matenal in ! m -
ton af tbi* aubehaptar mutt ami to the
aaekan a alAONETIZrO aUTTKlAL
|tae.tnj«M» »
-------
COMMUNICATIONS
9938
labe! u reqwred b> I 1" 101 and de-
KnbeO in I 172 ««
>ti fiyNC label Each raei»! barrel or
drun canta^unt a flammable licuiJ nam-
ing a i»oc- pressure oe:«eer 1C ant! 40
ps i a at 100' F must have aSxec a
BCNG lat>«' at speeifled :n ' 1*3 ISMi
ef Uiu iibchapter ir. add'tion to a
FLAMMABLE UQU3D label described w
IHJ41S
in rrroLOcrc AGENTS !•*<•: see
1 ITJ 444 a.-; : n: SBC or tnu lu^hnuer
for ETIOLOGIC AGENTS latent re-
quirement*
it - rwpry leo-f SM ' in 29 or this
nibenapter (or EMPTY labeliRc req-.ure-
menu
(hi Pcckatts eenfoinme temolt: £«•
eept u provided in «i 1T32: sne 173 (S
of this tubc.iapier a material for whieU
• reaionablt doubt nuu aa to us clasa
and labeiint requirements arc' (or »hic.l
» sample must b« ermniporwd for labor*-
torr analnia ma; b* labeled according
to (tie j'lipptr's tentative clui MSIITI-
men; OAICC upon—
el) Deft&isc criteria la thi* tub*
chapter
(2) The hatx-d precedte:e prescribed
to f ITJ 3 of Oat subcbapte.- and
(1) The snipper'* knotrledrt ef toe
material
(ii label; for OOT ivertfltttlm 111
and 110 unto A OOT speeiflcauer. lot
o? 110 tank must be labile; or. each end
aa required br this wbchapwr for tbe
hazardous aatenaj it coataln*
I 172.403 fUdioMSl** nu
(•) TJalet* exceptad from labellnc by
1 17WM or 1 17UU of Uua nihchapur.
•acn package of radioactive material
muit be labeled u provided IB tbu sec-
tion
(bi A RADIOACTIVE *-HrrE-i ubei
muit be aOxad to web pkckftct meaiur-
laf o A millmm or ioa per tour at mtS
point oa ta« aterau aurtaee ol (be
pa&Ucc. prondei tfie parti it
ID U act • fuuie CUa n or SL or
(2 ) Dow not eoDULia a "lane ouanurr1
of nAie ftetiTc maunai. ai daflaad u
I lliMt of uui nestuDtcr
1C) A RADIO ACTIVE TQfcOW-n
tabel mtut be attxetf to tacft-
(1) Package meuunng more titan O.j
but aoi men (b*a 40 BUUTBB per bow
at act EPICL ajui cot tueetiutf one < 1.0)
milllrta per boun at ttrte l«et trom
each paint OB Uai txumaJ lurftct of
•3) ruue Clui B psefewt
tnanon IBOOX of oat or tan.
(0> A RAPIOACTTTX TULOW-m
tobti nut ot oficod to toeb
ID kfMiwti aon than Bo mfflina
per hour at omeb point or trawl* oat
11.0) BUUroB PIT hour M tbrw lott
trom oaeb point OB the cxuraal lurloet:
(21 Xi a FMIoCUu m. or
(3> CoBUktu » nam OMandtr" Of
ndiateu*e maunaj u dcaaad IB I in.-
SnofUuirabebiptor.
Eaeb pockai* eoauiBlnc • rmtfio-
•ea*« maunU that ti*o afeu toe de-
fiaineB of oao or more addiuoBaJ buirti
muit be labeled at a radinarove miteru.:
•i rcvuimi br Uui tecaon me let toe.-.
additional nazard Pe: •• ameie
M) Poekafts conn i the lobd n!>
tnies of uranium c ;nuir. tnur. be
labeled RAOIOACTT .r.e OXIDSER
(2) Pattates eon: A| mine acid
aolutiona o! raojo»clive aatenal mull be
labeled RAOIOAC7TVE ud CORRO-
SIVE
if) Each paefcart required br lhu»e«-
tlor. to be labeled »IU1 a RADIOArTT.'E
label muit have tvo of these labels aJ-
ftsed u oppoute aides ot the paetace
(Btt 1 172 40C't> o> for freight eeaum-
er label requirement*)
«() Tb» fouo«ui apolieaftle item* of
Infoncanar. muit te entered IE the blank
apace* en the RADIOACTIVE labeJ ay
IftiSlt jnntmg 'manual erfne:hanical).
uiwi a duraole veatber rcauiut moaa*
of markini
"CoBtenu * The Dame of the r»-
dibnuclldei a* taJten Tram the lutmi of
neionueUde* la 1 1*3 J90 urmbou wtueb
conform to ettabUitiK radiation protec-
tion Mrminolorr are authrruei l * .
"Mo "Co. etc.) For mixtures of radio-
aueiidea the moat restrictive ndionu- '
elides oa the buu of radioimucitv muit
be lilted ai space en the la.be! allovi
(2) "Nuaiber ef cunes " Onit* thaX be
expreaaed IB appropriate curt* u&iu I.e.
cures id) miilintnes (rnCli or micro-
eunoi iuCl) labbrrvutioni art author-
UedJ Per a ftiatle maienal. the veitht
ta fTaaa or kUoerana of the saaUe ra-
dioiMtopt also ma* be maerted.
(1)
(h) Halioaaive maienaU label] re-
quired bv the Kfulations IB effect oner
to November 20. 1980. ma> continue to
be uied until July I. 1983
(«S FH «9939. July 28. 1980, effeeiive
November 20, 1980, immediate compliance
authorued)
I l^^M LaM« far eaUed earf ee»
MUtt poekoetiiff. When bacard-
eu autanali aanat dJffercat aaxara
tttmt are packed «ntbartfta> aame pact.
t«af. or witblD tb* aame evtaidi eou-
tAiBcroroTcrpaefcafdeacnbealDl in OS
aad autberued by 1 11J.J1 of tbt* eac-
eaaptcr. tbe paeuclni . ovtaide enntainer
or OTtrpadc not be labeled a* required
for eaeb elaat of baaartteia aawnal eoa-
Uiaed tberein.
arc ._ _
Btaocd within tbe MBM outside ~-"-'r~ ' 1TL40T
or oremcA. tb* wtude eoBtAiaer or
overpack muat be labeled u required for
oaeb class or baaardoua saatcnal eon-
it* place of Uie word -PO1SOV en the
POISON labe! provided the letter size
(.- r. color for CHLORDTE are the aame a*
•• ••- required lor POISON: H) A
!a5e: ma> be uaed U) place of
AMMABIX OAS and POI-
. label* required for Chlorine br
i .12 101.
lin.106 rUeratoi of UMfc
(a) Grnrral Eiccpt u provided m
paraerapht (b) and le) of thu section
each label required b\ this subpan mut:
be printed on or affixed to the sunace of
the pack aee near the marked proper
shipping name required b> Subpan 0 ot
thu pan
Exception* Label* BUT be printed
on or placed on a securely affixed Uf o:
may be affixed br other lultable meac!
to-
il) A packaee that conUlns BO radio'
active material aad which has oimca<
•OB* Its* tbaa those ot tb* requirti
label.
(9! Aeampreaaed tu cylinder: and
A pacicace wbica bat such an ir
rtniiar turface thai a label caaaet bt
•autfaeterily affixed.
(e) Placement oi muttiete labcb When
tvo or more different label* are require*
they satin be disparted or affixed next to
oaeb other.
label tortfcr. Each label must bs
affixed te a eackirouaa of emcrjrfj
color, or suit bate a dotted or «•-. ^ '-.<-
<*>l AddKionaf labeftn; '—>*: .-vM1-
ia< If required, tbe Ube; ".-- -» :•,
plared on at least two aid. -• s -.5 :.. x-
tatpliulmr tbe bouem> e ••
CD Bach paeftaa* eoBt*ua_a« a radlo-
aetl*e material:
«S> bcb paekate bavsas a volume of
•4 cubic feet or more, and
(31 Bach Otiiat eoatauer banni a
volimie of N coble feet er more, but leu
thaa MO cable feet, except when pla-
carded IB accordance witt | lT3A!2(b).
in PiacarOiBi Bay BO. be uaed to-
•toad of labcllBt OB a pacaart contain-
tat radteaetrve mawrtal.
(U) When labeled, one «f eaeb at tb*
appropriate laotb most be displayed an
or Baar th* clofure
14) Eaeb portable tank ba*i&r a rated
capacity of loss than 1.000 laUo&t. «•
oopt wban placarded la accordance with
1 173J14(a>
(f ) Obseorctf laaclt. A label must cot
b* oboeuToa by mertmn or attacbaeau.
1171.408
laM
(a) For a paekate eoBt
tbe word -OTTODr- ojayoeuetd ta tb*
place of tbe word -OZZDZZai* OB tbe
OSDBZR label prondtd the ittur aat
aad color lor OZTOEH are the earn aa
ttooae required for OI.IDI/.T.K.
(b) ror a packHe coBtauac Cbioraa.
tbe word "CHLORlNf ova M aee t&
(a) Xaea label. aflt*d to or printed en
i paekave mu»t b* durable and weather
itBtnasi Black, and aay ealor oa a label
aunt be able to vithnaBd. enthovt r^-
ctaatlaJ enaare—
«i> Jk n-turur fadaomattr tau tier o
deacnptiflB of ocvipmcat deeKned :or
thle PUIMM. ot* AOTK O B-U (11161.
or A8TU O tt-TO) ; tut
») A J»-«ay ooorjre to eoBdlBons
taetdaBt te Umniportauen that rtuoc-
atrty could b* ere-rf-i te b* eaeotmiepea
by the labeled packatt.
(b) fSacfi *"•*•""•* (aquare-oa-polati
THE BUREAU Of NATIONAL AFFAIRS. IMC.. •ABUNCTON. B.C. 200r
-------
215:0122
HAZARDOUS MATERIALS TRANSPORTATION
label prescribed in this pan must be at
least 4 inches (101 mm.) on each side
with eich side having a black solid line
border '/,-lnch (1.3 mm.) ft OK the edge
(o Except for size and color, the
pnnttrit. inner border, and symbol on
each Libel must be as shown lor each
label
A color on a Ubrl. upon nsual ex-
anun»tion. must f»U witi-.m the eclf
tolenuiees displayed on the appropriate
Office of Hawdous Materials Label and
Placard Color Tolerance Cf.tr..
iv A set of six than*, dated January
1973. for eompanacn with labels and
placards surtaceti «lt-K. pain:, laccuer.
enamel, plastic or other opaaue coatings.
or ink. may be purchased from the Oocr
of Haiiardous Materials Regulation. t'.S.
Depanment of Transportation. Washing-
ton. D.C. 20590. for JJ.50.
0) A set of tix charu, dated January
1974, for comparison with labels and
placanis surfaced wiih ink, may be simi-
larly purchased for $12.50.
(3) Both sets of charts may be inspected
in Room 6500. Office of Hazardous Ma-
terials Regulation. 2100 Second Street.
SW'.. Washington. D.C. 20590. or any of
the offices of the Federal Highway Admin-
istration listed at 49 CFR 390.40.
141 The technical specifications for
each chart an act forth in Appendix A to
or the United Nations Recommendations
affixed to a package in another country
may contain inscriptions required by the
country or origin.
[43 FR 34560. May 22. 1980. effective
November 20, 1980; 45 FR '46UO. Nov.
10. 1980. effective Nov. 20. 1980]
(i) The dotted line border shown on
each label is not par. of the label spec-
ification, except when usec1 as an alter-
native for the solid line outer border to
meet the requirements of §!";.406
proenaie tables in Appendix A to tins
(e) The specified label color must ex-
tend to the edge of the label in the area
desigruiied on eaih la be: except the
CORROSIVE. MAGNETIZED MATE-
RIAL. RADIOACTIVE YELLOW-II. and
RADIOACTIVE YELLOW.UI iat*b.
(f) A label may contain form iden-
tification information, including the
name of its maker, provided that infer-
tnatior, is printed outside of the solid
line inner border in no large: than 10-
point lype.
(I) A label may contain the UN and
IMCO hazard class number and. when
appropriate, the division number. The
mimbw must be—
(45 FR 74640. Nov. 10. 1980, effective
Nov. ;tO. 1980]
(I) Black unless it is on a COR-
ROSPrT label when it must be white, or
unless other colon are authorized by
this Pun.
f45 Fit 74640. Nov. 10. I960, effective
Nov. ;C, 1980]
(2) Located in the lower corner of the
label, .ind
(3) One-half inch (12.7 mm.) or less in
height:
(h) For import shipments only, s label
conforming to the requirements of IMCO
(b) In addition to complying wits
1172.407. the EXPLOSIVE A, 13PIX3-
SIVE B. and EXPLOSIVE C labels must
bt omaie. The priatlac and symbol murt
be black.
if) Cxerpt for s«e and color, thf
BLASTING AGENT label rr.ust b« as
loUows:
id) In addition to complying with
1172.407. the BLASTING AGEST
label must be onnce. The printing
t be black.
2.4l;> >0>4LAMMABL£
UM.
CA5
<») Except for six* aad color, the
NON.ru MM A.HI.F OAS label must be
MtoUowi:
KON-FUMMABLE GAS
Chwnicai ftoguiction Msjponor
tUe. 1TX41IUII
-------
COMMUNICATIONS
9938.2
215:0123 .
(b) In addition 10 (fit requiremtnu
specified in 1172.40?. the NON-FLAM-
MABLE GAS iabei must be_ereef) 'The
symbol and-- micnption musi be black or
white.'The solid lint border ind. if usri.
(he hazard class number must be the
color of the symbol.
|4J FK 746*0. Nov. 10. 1980, effective
Nov. 20. I9SO]
1171.416 POISON CAS label,
it) Except (or me and color, the
POISON GAS taoel muii b« a* folio**-
\ in aattjuoe to eomplrins
; 172.407 the POISON GAS laoe; must
be whjie. The pnnunt mur. be black.
•afi me irmbol must be black aod white.
| 172.417 -FLAMMABLE C\S Ub*l.
Except (or tilt and color, (he
FLAMMABLE GAS label miut be ai loi-
(b) In iddiiion to eomplytni with
1172.407. the FLAMMABLE GAS tebcl
fluut be red. The lyrabol tnd uucnpuon
must be black or white. Tbe tolid line
border, and. if uied. the hazard class
number musi be the color of the symbol,
-H? FR- 74640, Nov. it)'. 1*80; e'ffmive
Nov. 20. 1980]
i 172.419 FLAMMVB1.C LIQ11U UU-l.
in Except lor (tie and color, tbe
FLAMMABLE LIQUID libel miul be u
(b) In addition to complying with
4172.40:. the FLAMMABLE LIQUID
labe! musi be red. The symool and m-
jcnption must be black or white. The
solid line border, and. if used, the
hazard class numoer must be the coior of
the symbol.
(45 FR 7*6*5. Nov. 10. 1980. effective
Nov. 20. 1980]
• 172.420 FLAMMABLE SOLID label.
ti> Except (or me an£ co.cr. the
PLAMMASLE SOLID Uttci must be w
toUotrt:
overprinted. The rordi "FLAMMABLE
SOLID" auit not contact «ny red itnse.
The wruw stripo muit br iu(Ecitr.i!y
'iK&tr thin tht red stnpes to mike uerr.
•ppeir vtsualJ)- equal (n width
( 172.122 KPOVTANEOLSLY <:OM-
BL'STIOIX Ubrl.
Hi Except Tor tue tnt tola.. :ii*
SPONTANEOUSLY COMBUil ILLE
tobel muit be *.' (ollori •
(b) In addition lo ecmclytne
| 172.407. the SPONTANEOUSLY COM-
BUSTIBLE label must be red ic the lower
hiJf and white « the upper hall. Toe
•rmbol and pnatini must be black.
ic> If use of the SPONTANEOUSLY
COMBUSTIBLE label Is requiree by the
RfuUciont of another country, it may e
wed in addition us the uH*i» required by
|| 172.400 and 172.402.
i 172-123 OANCEROCS WKE\ *TT
Ukcl.
(a) Except for itteaad color, the OAS.
GERODS WEEN WET labeJ must be v
tollovt:
la Mention :o ceni»lyiac
: J7S.WT. (he riAMMABLE SOUS label
mutt be white rttti terueaJ red *irtpe>
tquatlr tpeiceO ou each aide of a refl
atntln tbe eenier of the label. The m-
(k&lle (or tbe wonli -FLAMMABLE
•OLID- muit be wtJte. Tbe pnnoni and
lyabol muat be black «itb tbe
hT THE BUREAU OF NATIONAL AFFABU. »C.. WAfHINGTOK. B.C. J0037
-------
215:0124
HAZARDOUS MATERIALS TRANSPORTATION
• (b) In addition to complying with
1172.407. the DANGEROUS WHEN
WET LABEL muii tat blue The symbol
and inscription muii be black or »rme
The »ohd line border and. if used the
hazard clan numoer must be the color of
the symbol
(45 Fit 74640. Nov. 10. 1980. effective
Nov :«. I980|
•Cl V we or the DANCOIOU8 WREN
WTT label ti rtqiurcd br (be regulations
o: uioUter country, it ma? be used IT.
adCLixm to the labels required br
it m«ooftfidii2.«o:.
{I72.436 OX1DIZER librl.
«a i Caccpt lor aize«&d color. the OS3-
DIZEft laocJ BUI: be a> followi (wt
11~1 4« lor anthemed Ubtt ojoOlftea-
beu>
| 172.430 P0150V Ubcl.
la) Cunt for cite and color, tbe POI-
SON Ubtl must b« w (oUovt d« | n: .
40J lor autharuec label modification)
idi Tbt prtaent and irmbel must be
black OB a wluie baektraund.
1172.436 «AOIOACITVE VBTTE-I
bbcL
(a) Excepi for sue and color, the
RADIOACTIVE WHFTE-I label muit be
at follows'
ib< In addition 10
i 172.407 ttt POISON la»tl BU»< be
wbiu Ttot pnatinf aad nattol muii be
(•i Zscept (or KM and color, the IR-
RITANT lafeal muit be u loUovs:
•t i In addition to eon&lrini
I JT240J .he OXIOBOt label mm: be
ytllov The pn&oat a&d irmool suit
be black.
' ITS 127 OHCAMC PF.ROMDK
•» EI.-.VUI (or MM and color, th* OR-
C<«N;C. PEROXIDE label muii be a*
|4« FR 49939. July 21. 1980 effective
November 20. 1980. immediate compli-
ance authorized)
ib> lu addition to complying with
i m.«r (hi RADIOACTIVE WTCTE-I
latel mu»t bi whit* Tbt pruoat and
•rabol auit b« black octpt lor the "I"
wbicb »u»t o« nd.
1172.43* RADIOACTTVL TTLLO^-II
(•) Except for tize and color, the
RADIOACTIVE VEU.OW.II ubei must
toe at followi:
ibi la addition to oompimc
I ITJ.iCI. th* nWTAKT labed auit bt
vhita. Tie word -fltlUTAKT" mutt be
tc eoaptytaf with
tb* OROANIC PDIOXZDE
taMl Biut b* rello* The pnctact and
•rsftul uiuki bo black.
-------
COMMUNICATIONS
9938.2
MtZ-U
21UH25
(4! FR 49939 Jul> 28 1980, effective
November 20. 1980. immediate com-
pliance auihorued]
(b> IB addition to eoaptruu with
11T3 «07. fee RADIOACTIVE TTUX3W.
C UM BJUK be MUOW la the top ball
•ad wall* u the lower half The pmc_i
•ad irmfcol suit et black, except for UM
•XT which BIU . be 1*4.
1172.440 RADIOACTIVE YELLOV.m
aaae u the lower border Biut.be a*
toUoft.
(t) Except for tee cat aad color, tto
•AD10ACTTVE VEU-OW-IH label suit
boaefoUowB:
(b) For expert aolpaeau U u*e of the
foUDwiai UMl 11 rtgiurad or ta* ropilf
aeai or aaotaer ceuatrr. it may be uied
la Mdiuea to the 'aot! required IB part-
•rapii u> of tate (otooB for Etioiorc
atecu la addiues tc eompinai with
1173 407. tail additional Ubel for Euo-
lofle aceau. except tor uxe and color.
BuitfeeatfoUew*
OANGER-PELIGRO
H! FR 49939. Jul» 2S 1980
November X. 1980. immediate coir.-
pbanct authorized]
• »• IB aecutioe tc cempinac wtth
I in »C7. the RADIOACTIVE TELLOW-
IS label suit be yellow la the top nil*
tafl wait* ID iDt low»r aalf Tbe PHBOBI
•ad trrabol a nit bt blict. except tor Uw
"XXI" waled muit b* ret
ibJ The CAROO AXRCRAFT ONLY
Ubel mtui be » neuatic meMurtce 1«
tnettes 1110 mm.* tuth by +'.i taehek <120
mm i «Mc The pnnuoc atut be bUdc
and the irmbel muit be bliek »ud
ermate.
1172.450 EMPTY UbL
<•) EMtiafPTVUael. newt lor me.
nun be u Iollovi
beret tor itzt «Ad eclor
CORROSTVZ label BUT. bt w
tbe
<•> txctoi tor tat and color, tbe
MAONTTSCB UATOUAL label Ukclud-
lag Uie UMJ Bant la lae tower boraer
Biut b* u tollav*
-CORROSIVb?
MAGNETIZED
MATERIAL
EMPTY
(1) Eaea atfe aot be at taut 8 taeba
HS2 SB.) wite «ach tetur at le*it i laea
OS.4BB.I iBBMCbL
it) The label BUR be white nib black
pnaoai.
n> la aamuoa to ooapljtac with
1172.4VT. ta* COKR08XTX labal suit b*
•nlU D tae top BUS aad black la tat
half. Tat pnaBai BUR be walto
tbe oatal suit be black aad wan*.
CW Tte UAOHCmiD kiATOUAL
total Han be s ncuatf*
taeaat IK HB.I feitf a
nio KB.) «to*. T&»
blue aad ta* •Trabol
u> Caen PBMB wao offtn tor tnu-
ponaaoe or traatporu any buardout
•awnal nibiect to (bli ntbcaapter ehall
eomair with tae apptieabU
nqttnoMBtt of lait mbpart.
(b) Tan oaapan «o« an apply
(ItXualocici
BUI b* wblU and
U7X.44I CABCO Anourr ma
1171.444 rnOLOCICACEKTUM.
(Ay) BftCh pftttkAeft *^T***<**l»y ITt
lane acwai mbj«et to tale •ubchwwr t,> deept for
•on be labeled a* fpectttti & 1173 JU CAKOO AZRCKATT OMLT IDAJfOEH—
•fthjinbctaapttr. FTllQROt tea*! tactaduw the
foftlMbtd br THE aTURKAU Of NATIOMAL ArFAOB. INC. *A«trt6TOK. D.t 100T
(2) rUiardeus mteuli
ORM-A. B. C. D. or E or
(45 FR 14640. Nov. 10. IMO.
Nov. 30.1980]
U) Hacardeua sattrlala anaoniM
by thtt nibcaapicT to be entnd tor trmai-
ponaaoa a Uavutf Quaamiti waca
tdcBtmtd u neb ea ihipptai paper* at
iwtthllTZJaiib).
-------
HAZARDOUS MATERIALS TRANSPORTATION
tVDkifcilad platuduf.
(i) Except as provided in ptnfnph (e)
of this iccnon. no person may affi» or
duple} on a portable link, freiihi eon-
umrr' motor vehicle, or rail car any
placard described m ihu lubpan unless—
(«2 FR 6:019, Scpi II. 1980. effective
nunediaiflv)
il) The material being offered or
traaiponad U a haaaraoui maunal. aad
Tht placa.rd rtereaeati • haxard
of the hazardous ma urn beinf ofl«d
crtiaaaporud
Tb> No penoD mar affla or display any
atfn or otter dene* OB a motor vahicU.
nil ear. portable unk or frcu&i eon-
uuacr. thai tar tu eolor. daucn. shape.
or emteat could bt cootuaee wtb anr
piaaird prescribed in this wbpan
(e) The restriction in paragraphs (a)
and (bl of this waion do not appN to
portable tanks, freight eontainen. motor
vehicles or rail can which, in addition to
an> luacardi requited b> ihu Pan. may
be placarded in conformance with the
IMCO Code
(4; FR 62079. Sept II. 1980. effective
aiitely)
lotatlfkadofl amber dbptey «
liacaitfs.
[45 PR J4S60. Ma> 22. 1980. effective
November 20. 1980)
For procedure] and limitations pertain-
m| tc> the disala* of idennncauon aum-
bcrt on piaatdi. tee f 172.JJ*
• 172.504 Onml pbardme require. Jmauai «M»»
II Of motor KUU mlcar or fr«|ni cmuiatr
eoniuiu i nuitnaJ tuute teocnbfdi u—
Thr monr Kfurn nn car «r lm|ni cmuiiw
nil* tc pliardMOTitcn uMino ucx n>« —
A.'
a >
ajlDlOACTTVl >•
Mnthu tADIOACTIVE'AKD CORROIIVE •
HBIRT «••• lUDIOACTIVE1 • AND CORROSIVE •
'EXPLOSIVES B *IMV« MI muifM * a» trr**< conuixt Motor •»««* or »>l c
A t*~a*m M* B oUtira* EXPLOSIVES A u no.rml .,,..,
•FLAMMABLE SOLID -w pn«i« u nvime win >hm IIH DANGEROUS WHEN »ET Ufrti n
ue I'JJffte; br Ml ate Hiipntgu of iwun
Ulm* mmJi trmtr, •»• nttftnit >»t»«ji a •» ITJJ921H
•COKKOIIVE man npi m»m< »cr Hiipm^n «> !• thu tOOO parttti ran »ii|Hi
,„ a*. .S. |
Mnntli •onui| ikf
TABLE:
If II* mm KIUCIC ml ev or lmv» COHUIIM Th« notoi >«iKli >mi< ur o- rm|«i canuino
•MIM i iBumil CIMMB ittamaai u— mau bt paaraie on ntn pflt ma atti cnc-
aiiMBiiaiiaun syv
iwentrvauu pi lOuennti
Non/tanaMH pi iFfnonnci
Monftunuitu pi lOiypa.
Mure
. DANGEROUS ' ' . .
•LASTING AGEWTS * I0.
NONFLAMMABLE CAS '
.. CHLORINE
... raises .
• OXVCEN •
. . FLAMMABLE GAS '
. COMBUSTIBLE LIQUID ' '
FLAMMABLE ,
FLAMMABLESOLID '
OXIDIZER "ff
. ORGANIC PERIOXJDE
DANGEROUS
«BI Cuept BJ otaBrvuc prondad la
this tuficAapicr eaca motor viiudc rail
car. iiad frwc&i eenuiDcr oonuiniBC
anr uuaaucr of a haardous material
BU» M placarded on aact and aad aaea
aidt A trtuht-BMtalnar. mowr
cJe. oi rail ear onnuinmi two or
^IAJMH. af fliAMflala rvQiuruc dffiffCBt
•BMBrti Bpactflad a. TaWi 2 mar be
placarded DANOZHOU8 m plaee of tba
annrau r'"**~"**f iPecAci lor aacb
«f tbaic -"— af maunal tpaciBad to
Thbl« 2. BOWCTBT. vbca 5.000 pounds or
BBOTB at on* claaa of maurtaJ •
tharatti at one lamdlv laettttf. (be
piaearl tpaclflad for that elaai m Habla
a auri ba aoptiad. This parampb «ea
i appJj to a pBtUBte unk. eano taak.
|45 Ft MMO Ml} S. IBB. tJImani Mo««w ». !••>. IS Fl «*•!». Jttr 10 ItB). iff
IAIPMJ only IP • ctw C CVIOBM ngvrad w bt KMM vnb n EXPLOSIVE C I*M1
lOXYGZN pfcaru MT *t «• IP IMBUIT tByrW pnwnua •»» MIH* • t mum
MI •• it* aHinMc • HC. m JtD of iaa BMUIB
KOKO'JSTIBLI o**n iwuma «N *Aa i mmu diud « i mBuwMi kaiud a
• I
to n too
ui we. I FLAMMABLE «uar« our at
i CANGUOUS WHEN WET law •
PLAMMAILE SOLID .
• ff. I1LMI (}• BM I. (to
(e) KB plBCtrd U rawlrad OB a—
U> Motor vBhiela. or a
talriaT It marpenad br Ucnvaj oeUr
ooDtaliiiac IBBI (ban 1MO pouadi
•BU n«ai vatcbt) of one or
.emnd brTkbla L or
*CMLORJNC pkord noiina e*r to i
NON-FLAMMABLE CAS tmavt for
»A NOS-TLAMMABLE CAS
iBXIWOI
I AGEXn. OXIDIZKR mt DANGEROUS plaeM
tar ««rii. tr nil ar MM axuatOmu A er B •«•••
jijT«a«tJ91UDIIER
MrlO."lBB9|W *^"
(d) Any partaiini havini a capacity of
110 pilODi or leu than contains only the
.randue of B haavdous maienal covered
tar Table 2 of this section teed not be in-
duded in dctemnmni the appbeaburry of
an IB
I FLAMMABLE CAS
lOStvu A*or'
• ktaauxdJti
•LASTING AOfKT MI
E (£.:
IS FR M560. May 22, 1980. tffacove
20.19W|
M alroadr plBnaniafl tor taa aaa-
l aa iMnme BT tola Bubparv
(I) No motor earner Buy transpon
a hazBTdout materul in a motor vehicle
BBtai toe placajdi raqutred for the hu-
Brdous maianai arc affiud (hereto BI
required by ihu aubpan.
»>']IUU ev ka4ad with Imgbt CBB-
TBBiclat whan aaea
or Bioter fihirla oon-
_«) of OBI or Bon maunalt,
lbrTahle<3>.
Thu paamcraph deaa not apply to port-
•bta tanta. earto taaki. er taak can er
to BuiportBDoa by an or wuer.
II1UM fii Ulai mmt
a^iiUa*«^.
U) Each penes effartai a i
rtB B haATdous malarial for t
toon br hUDvay abaU pronde to tbe
ewntr tba raouuvd plinarda for
rul beat offend prior to ar u
tlm« tba matanaJ uoflarad for
MBguUtion I
Kb***?.
&FR 5298. tea. 19. INI. tfleetrve
.1.190]
Eacfa moior vehicle mod to transport a
packaax of Jartt quantity ndioaeuvc
nuenaii (act Il73.389(b) of ihu rub-
chaster) must have the required RADIO-
ACTIVE mwviag placard placed OB a
•*•>. truer] „
-------
9938.2
COMMUNICATIONS
215:0125.1
tquare background as dncnbed in
Placarding end affixing plac-
arts: nil
«*> Sac& pence oflafl&i a haiaTflou*
aatan*i for craateartauon by mu aboil
affix la the rail ear enrTiinmt U>« mate-
rial. toe placard* tpeOBed by tfttt fu&pon
tor tbe material unite* tBf pjoeorda al-
ready diniaycd OB motor vesicles tru««
pen coBtauim or portable (Ufa that
ore u a roU car eomsty with II l?2M2
Mtf 1TUM M IbCM atcBoai BerWlB V>
ploearaiBf tbe rat) cor
tt> He rail comer may aceepi a rail
eoi eoBtainlBi • bacardoin manual lor
traaipanauoc ualeu the placard* for
the bo&udoui naunal are affixed
theme ai required &r uiu iu»part
1 171510 Spinal pbcatrilnt
nil.
DOUE placard Each domed Ualt
ear TT"*"""T a flamaa< liquid hit-
be a meet omivire exceeaat It UJ-
otaoa* r U'.«' C.i Butt ban a DO1CE
placard aCxec: thereto u iptelflcd In
1 17.1 nut) at Uui jubcflapter
ie) rw/TP placard Each eapty task
ear must M placarded wjtt as DoTTV
placard ai required and described la
JlTliZi or paratsmsh (*i of tha aee-
(UB, u appropriate that corropOBO w
(be pUcard that *u required for the
material U* unk car lait eoouioed un-
IMI (be tank car last eostataid a Com-
btuuui licute or bat
Hi JUJMdrt vtui
)tct to thl* labebaptcr. or
U) BufflattUr elnntti c< raldui and
purt«d of vapor te rtao>« aor peuatli'
«4)
placard «ae6
. motor *•&!(!(. one
roll ear coatauiac ladiax titat bM bcea
TiBBinstd or trcat*e vtu pouonoui
llouid nlid. or cu. a&d tbai li offtrtd
lor naapwifttton ti i«U awt bavt tbc
placard ipKifletf to I 111 428 e( UUf sub-
cbaptv aflUK oa or atar o«ch door.
| ITUlt Fmoti
who offtn t«r omaipona-
O0n * batamoui mattnai ta a trvc&i
»-•«-••» mnaf • ctpacitr oJ Ht cubic
ten or am ahaU ofis t* uu tracht eon.
Coiatr tat piacarda ipKiflrd for (te aw-
tacui IB aeeotOUM with I ITL&M. Bo«-
OTOt« _^^*
ru Tbt plamrrttnr wetpoo* prcnwc
to i mae* *cxl) oppuot, aad
(It tb* pUcardJa* oetpiM pre»ldtd
tV MftpanmMu 'O'l) o&d ie> (S) of
I HUM WDUM to neb M«bi OOB>
tataar btai «aipon*d tor dtUvtrr le
ataiy lollcwiac aa
(b) Cspoctty la iktn HO attic /m.
tact pcnon who often for (natpona-
oon by air a baavdoui matenaJ u a
AwaiH container sevuf a capacity of
tan than 6*0 cubic fen shall affix oat
TNI
placard of the typt ipecified bv para-
graph (a) of ttui icction unleii the
frcithi container ti labeled in accordance
wnh { 172 ObeXJ). or conuint radiotciive
iBitenah requiring the RADIOACTIVE
VEUOV.- Ill late: and u piaardcd with
OM RADIOACTTVI placard aad a
loaded la oeeardaacc vitb 1 172.lMi*>
Wbta aacardou* auurUlt art offend
for enacpoftaBa& aoi larolffec air
traatponaUoB. ta a Irugfat container
Baviai a caeaeity or leu t&os MO cubic
f«K. tbt fiwcbi coauiiter a«*d aot M
placarded. Bovever. it sun b* iabtUd la
aecarda&et «ltB Bubpan £ or tali pan.
. ic) Motvu&iuaaizu patMroea* ta)
and of tftu MCUOB. podcarea wn-
tai&iag aaiordoiu awurtali. other Una
OAU-O. offered for troaipenattos By
otr la fraitbt eaatoiacn on ra&ioct to
tht taapecUoD rwutrtacau oJ I WS JO
of tali chapter.
f 1T:J14 Uifo tank* and porubltianki.
(a) Each perwn »ho orTen for mm-
ponmon i titfo tank, or a ponible unk.
wnuminf i hatardout maierul thill
affu the piacardi ipecified for (he mi-
ten*, m accordance »ith f |72.SO*»)
However, if placarded tnnud of libeled
01 provided ing I72.406fe)r4) i portable
tank hannf i rated npactn of leu than
1.000 filloni need b« placarded on onlv
1*0 oppoiiK tides
Raloaded vitb a aaicnal aot tub*
Joct to UUa fubc&aptcr: or
(2) Soflcieatlr do%aad oad purtod of
Toson toremcrte oar potattol bocord,
aor cote ai leoat J lacbtt (II0 sin i
a»iv from tuch marking
(5) Have the words or identification
numbeP(»nen authonxcd) primed on u
aisplaved hontoniall). readmj from left
(0 nghi
[41 Fit 1*640. Nov. 10, 1980. effective
Not 20. I9SO)
(t) Be maintained by the earner in a
eondluoo ao that tba icroat. UfJbUity.
color, and nubllltj ot tht placard »U1
aot be ft""'*""'11? raduced dm to dam-
•l«. datanoranon. or •bacunmint by
dirt or oUitr matter
idi RceoBtBinded (pKifleaooiu lor a
placard holder art m forth la Appendix
C of thii port E*eept for a placard
Bolder uaOlaJ (o that caatatned IB Ap-
peadu C to ttui part, the aaan* uiee to
attoeh a placard BUT an obacure aaj
pan of Itt fUTlace outer (boa the berdert
Mt*l MMciiiuiiani Ur
U73J1C vubibtr
pUc-
la) Each placard on a motor nhtcJt
aad each placard OB a roll car ouat be
tmOUt wibU fraca tbt direcoan-it loeea
coetpt MB ta» dlraenaD at B&OIBK
awtor nbidt or roll car to which the
iMfttv vvfticiti or mi citf »ta OVQBM&, Tbts
fBimiMiaif mil in • - TTttii iiliinriti
Oapltved on tat fmihi ccnuinen or
portable lonks loaded oa • swtor vehicle
or ml car
(b) Tin required pUcordinf of the front
of a motor vehicle mi> be on the front
of t truck-tractor uuiead of or u addi-
tion to the placarding on the front of
the orio body to which a truck-tractor
• attached.
(c) Each placard of a oincport ve-
hicle, ponahle toak or Mtjht eoatoiaer
(1) •
Hunto or plootd to a bolder
Ua* APPCBOI c w tbu pan.)
(3) •• looatod citar ai appanc&a&cta
oad dtneei weh u toddrn. tapea. door*.
Ill So lor oi practicable, be teaud
•» tut ean or vaur u on AMCM la
tt inn (he wteela ot tbt ttureon
(«} Be loaoloa a*»y tnm tar aiafk-
tv (facbai aa>enutBt> (bat could aub»
nooee id tfecttfeaoH. aad In
ewrt pee* • T»»J«t«t
(a) A placard ma? be node of oar
aloauc. actal. w other awtonol that la
equal to or better IB atrennb and dura-
btutr than the toitoard apeefled In
parairapb (b> c* Ifau aectiea Alao. (*-
Bocovi or ntmvfieeQTe maienolj mar
be wed OB a placard proridlac the pro
toibed colon, ttraafth and durabtliir
art maiBtatmrt.
fbJ A placmrd Bade of lafboard must
be of tftaiattal tnat baa1**
(I) A quaiur at laaet eaual to that
Aotitnaud oomBwreUllT w «hiu tot-
board:
<3> A wetiht ol 195 POICPOI per rttre
of 2* by U.&UB aheeu.
(1) lae atlllti to paot a 40 pal.
MttUia ton: aad
«> Ibe oblUtr to vltbatond open
weather expecurc lor 10 tfen without a
mM"T"**' reduction tfi oSecttnaeu.
(c> A placard, BU7 eontaiB torn idea*
OneaUon tafarmauoB. ttidudi&i the
BOCM of «a Bofcor U that intenaatuB la
prtnud ta (be oner tt-UKB (12.1 mea.)
border at ee Urter than 10-pwni rypt.
(d) The huard cius *nd dmnon
Burnbcr pnaenbed for dangerous good!
to the UN RccommeAdationi titled
"Transport of Dangerous Coods" m»\
be eoiercd in the lower corner of the
diamond on eacb pUcard. If t placard u
toed 10 display identification numbers
as auiBorued by f 172.112. tl» clasi
aumber BUK be catered in * oumcra)
•ppronmttely IW ncnes (45 mm.) in
boghi iBumenl btight stay be between
1 3/1 ttdia |4l mm.) *&d IM tnehei «J
•a.)). It must be black on each placard
cjurpt when on a NON-FLAMMABLE
QAS. FLAMMABLE CAS, FLAM-
MABLE. COMBUSTIBLE or COR-
ROSIVE placard. Tht cJau number on
a NON-FLAMMABLE CAS. FLAM-
MABLE CAS. FLAMMABLE and COM-
BUSTIBLE placard may be while or
black Tht dau number on a COR-
ROS1VE placard must be white, and on
a COMBUSTIBLE pUcard with a white
bourn at prescribed by IIT2JJ2UK*).
MATRONAL
INC. WA*N(NGTOrr OC 10077
•*«. irut««g *
-------
COMMUNICATIONS
215*127
the class number must be red or black.
(45 FR W560. Msy 12. 1980. effective
November :o. 1980: 45 FR •4«40. Nov.
10. 1980. effecme Nov 20. I960]
'«• 8\:rt»ce pitmer.uuor. en t placard
must mwt the (ououu^i rwuirerneaw
Mi Burk ana any color must be
able to withstand, without sulivTintlal
ciiiini*—
•i> A 7j-hour fsdeomeur test if or *
description of equipment desunefi for
thw purpose. MT ASTM 0 23-.
or ASTM O 2S-70': and
Mi) A 30-dar exposure to opea weather
conditions.
b) -In addition to meeuni tbt re-
quiremenu of 1172.518. aad Appendix
B to thu Pan. tbe EXPLOSIVES A plac-
ard must be oraagt with a h inch (13.7
nun:) wblte outer border. Tbe irmbol
aad pnnt must be black.
$172.523 EXPLOSIVES BaJaeard.
(a) facept for ilte and color, tbe EX-
PLOSIVES B placard murt be ai follows:
/
N
/ V
/.-'Cx'
/.:••#::>
/
DANGEROU
^N^Egfv*/'
\ ... -"//'
\'. /
vx
• b< In addition to meeuac tbe !*•
quinmrntt of 1172.319. aad Appendix
B to this pan. the DANOEHOCS plac-
ard must bate a nd upper aad tower
tnuifle. Tbe placard center area aad Vfe*
If* (12.7 mm.) border muit be wbJU.
The laaenpaon must be black with tbe
ib*lmcb (3J mm.) border mafkar to the
vbittt area at each tad of the iascnpuon
red
1173^22 EXPLOSIVES A »U«nL
(a) Except for atte aad color, tbe EX-
ir< A placard must be as follows:
(t > la addition to rneeuaj tbe requlrt-
menu I 172J1B. and thi* pan. tbe EX-
PLOSIVES B placard BUR be oraan
wttb a 4-rneri '12.7 mm./ whit* outer
border. Tbi tnnbol and print muit be
H72J34 HASTING AGENTS ptoewd.
(43 FR 57897. DecRnber 11.1978]
(a) Except for oe aad eoior. the BLAST-
ING AGENTS placard man be aifcUow
(b) In addition to meeting tht require-
tnetra of this pan. the BLASTING AGENTS
placard man be orange with a '/i-inch (12 '
mm) white outer border. The printing murt
be black.
| 172.525 Sund.rd rrquirrmrnu for iK*
CMPn placard.
OB tbe iwvtne aide of a placard, or
(» A eemposlte made br eonriai tbe
top ertaatf* of thi appropriate placard
vttb » btock trlABtle baartni tbe word
•tawbiuietttn.
1171527 iiriimnil nqilnmtna for
orate placard*.
(46 FR S298. JIB. 19, IM1. effective
M. 1.19*2]
(a) Except for rise and color, the
•quire background raquired by 1172.310
(a) for certain placards oe imQ cards, aad
I172J07 for placards on motor vehicles
ooouuning i package of large quantity
ndioactive maiehals. musi be as follows:
3>274'l
(toe. mortal
fubiishe« BY THE IUKUU OF NATIONAL AMAlHS. INC. WASHINGTON. O.C 20037
-------
9933 -2
215:0124
HAZARDOUS MATERIALS TRANSPORTATION
Except for ttz< and color, the NON-
FLAMMABLE CAS placard must be a*
^OXYGEN
FLAMMABLE CAS
(a) Exxept for tit* aad color, tbe
riAMMABLE OAE placard muft be a*
ioUovs:
(b) I& addJUon to meettnr tbe rtculrt-
Mnt of 117J.S18. and App«adU B to
tbti Pan. tbe NOK-rLAMMABLE OAfl
placard mutt be men with tbe frmbol.
inicnpaoi. and >i tnct (12.7 mm.) bor-
dtr vbiu.
11TLUO OXYGEN pUcaM.
(a) Btetpt lor AM and color, tht
OZTCXN placard mutt b* a* toDowi:
/•••
(b) I& addition to mMtiiic tbe re-
enuremtnu of 1172.519. aad Appcudu B
to tbti part, tbe POISON CAS pl»c.-..-3
mun b* a white 10% aches (273.0 mm.)
•quare-on>point with a Vi-tncti (3J
mm.) black wild Un» border ',4-tnf;i
(117 mm.) m (ram each edte. Tbe ir"i.
bol tad UucnpUon aust be bUcfc.
(b) IB addition to mMUni tbe rco^iir*-
"menu ol 1112J1B. and xppcndu B to
tbls Parv tbe FLAMMABLT OAfl plac-
ard au*t be red vjtb t&e crabol, mtcnp-
tion. and H t&eb (12.7 mm.) border
wtut«.
| 17U36 OTLORINE pUeanL
(a) Biefrt (or alxe, tbe CHLORINE
placard mutt be a* (oDo*f:
17LM2 FLAMMABLE plcetrd tnU
•Wlftcilion.
(a) Sxcept (or tixe and eolo:-. tbe
T.r placard must be es lol-
CHLORINE
poiBt with a H-tach (3i
mm.) M*>* oalid lae benter H»mcli
(12.7 ma.) to (TOB each edye. The trm-
•ol aad iMcnpoon mart be black.
(bi ID addition to meetinj tbe r»»
cnumncnu of I 173J1». aad Appendix B
«D ttUi pan tbe FLA1OCABLZ placard
muit be red with wbite tymboL laicnp-
floa. and %-taeh (U.7 mm.) border.
(e> Tbe word -OABOLXNV ma; be
«Md a place of tbe word TLAMMA-
BLT" OB tbe placard that-ta
-------
COMMUNICATIONS
215:0129
oc a cano tank or poruble u&k being
usisl to transport rasoUoe by highway.
The wore "OASOLDfE" must be in let-
Urt of the tame slic and color as those
IB the word •TLAMMABLR "
| 172^44 COMBUSTIBLE pluard ah4
modifies lion.
Except for all* and color, the
COMBUSTIBLE placard must be as
fOllOWi:
(b) In addition to meeont the re-
quirements of I 172.118 and Appendix B
to titaed DATX» wise CO&CBUS^TXSi^^E fi^iVCs^rd
mutt be red with white lymDoL. inscrip-
tion, and H-lneh (12.7 ma>.) border.
it) The words "FUEL OH." may be
\iaei in place of the word "COMBCST!-
BLE" on the placard that is displayed
on a cario tank or portable unk beini
used to transpor. by hlchway fuel ell
that Is n« elaised as a flammable liquid.
Thu words "FUEL Ot" must be to let-
tcni of the same alee and color u tboae
ic 'the word "COMBUSTIBLE "
FLAMMABLE SOLID tU«*-
atd.
(«) Except for
•* toUowi :
au« and color, the
SOLID placard must b*
1172.348 KL4MMABLE SOLID W pUc- | 172JS2 ORGANIC PEROXIDE
•nJ. ard.
(a) Except for size and color. tb»
rLAMMABLE SOLID W placard must
beufoUowt.
Except for sue and color, the
placard mutt be a* follows:
•'. ^^
FUMMABL^
sf% ifb. I I •b> i^"^ •'
SOLID %/
'•• '• ••: 8 '/
(b) I& addioon to eonplyiBC vttb
1172.811 and Appesd&i B to thu part
!&;• w|,Atn*A«Tj y>t.Tp placard mint
be whiu with men Ttmcal r«d ftnpei
• awt a H-tnch (11.1 mm.) wtuu bordtr.
Tbt armbol and mtcflpttoa not bt
bteek.
^
OXIDIZER»
RGANIC!
(b) In addition u> meetinr the re-
quirement* of 1172J1>. and Appendix B
to this pan the OROAMIC PEROXOr
placard must be yellow with a Vj-toct.
(13.7 mm.) white border..The symbol and
tnacnption must be black
I172JS4 FOISONt.Ue.rd.
(a) Xxceot for ilxe. the POISON plac-
ard man bt u f oliows:
(b) to addition te mwtttoi the raqutre-
•Ktt el I ITUie, aad Appemflli B to
tt* Part, to* POISON placard nut be
wtth a fc-mch CSJ am.) black
ttM border H-taefa (12.7 mm.) In
ttM *dtt. Tne omboi tad .macrtp-
(b) In addltkm to mwttinc the n-
«uinmnti of 1173Jl». aad Appendix 8
«o ttus pan, the "«""-"a placard
mnn be reJlow with a ^-inch (13.7 mm.)
vbitc border. The crmbol and t&eoa
| HUM BADIOACITTE pUc«4.
-------
9938.^.
215:0130
HAZARDOUS MATEAIAISTRANSPORTATION
color efttm buri or Tabit : IK intended for
. uit WILT, itxii and plaarai sufficed onJ> vjih
inki.
For labels primed directly on picki(in| sur-
face. Ttble } miy be uwi. atthoufr: com-
plianc* with either Ttble > or Table 2 J ruffi-
cent Howrvct. if visual reference md.iiio
thai ttit colon of libels pnntt: airtei > en
package suffice are outside the Tibit 1 er 1
tolerances, a ipenroohoiomete: or other
inicrumemaiion mi? be required 10 insure
compliance with Table 3
T*att I .-SpKificetivu for Co/or Tolfma Ctero for Use With trie* and Haatti Sur/affi
W\tk ftmi. Lfrover, Enamtl. fianc. Ottitr Opaque Coetintt. or lit*
Cftior/Scne
MunatU MUiietiu
C1E dra far sour:e C
Y J >
DU FR 2*47. April 16. 1979]
lb> la ^i^tiap to ACCOM tbi rtqvdn-
menu 01 I 172-S1B, tad Aroencta B 10
tfeii Dirt. toe RADIOACTIVE placard
mutt hurt the top portion raJlow w«6
. Tbc lover pomos auct
tad Uk< toaenpaoc
|17£5U CORKOSTVE »UeanL
(») Eae«pt for «1», tte CORROam
placard nuit bt u
Ik....
, , «l« • ••!«
»«0 *n,u
._ , , -- » «•"/!«
i:oc
HOC
.to
"Tfl .
rv.«-
Parpli
Gnatnt mxc)
Onnui
L*r.
Out
. ,. »«*• ••'"
1 *fYF 1 A/!t
'PTT »•'!•
1 U
M.M
tui
K.10
M.10
H.1C
H.10
(i.:o
SVJM
13.04
ILOC
11M
11 5?
M.M
at. OB
n!oo
w w
Of .CO
1100
Ot.5«
jut
j*;i
JVI
JM]
JI10
Xi:
Jin
JW«
.410
.MM
.tl)."
.«:*
,4C»
.«it4
.UM
EM
Jill
.C14
.49:9
«»i:
.014
.IUI
AVH
.Ull
4*U
«rr.
4k 1»
.1)^4 J»5S
JiJI 11H
J]W Jit]
j«n j:^
.IHI 4111
JJn ^4149
.(Ml
tut
,15t«
.IK!
.ins
UJT jicn
(b) IB addition to m«uaf Uw i*»
tnuvawca of I fTUit. Bad APPCDCUZ B
to ttila put, tht COKPOSm
Btnt b«Te tbt ecnt« ud lewtr
blMk CKwat tor ttc teoera la ttit vert
-cowicsmr whida mwt bt «hiu.
The tymbol nun b« oUrk and wtuu.
AmiDtx A—C»mn or HAZAIOOUS
kUntuLS RicuuiWN COLOI TouaANa
CHAin AND T*IUS
(FR2I4CT. April l«. irrV]
The foUo*irn art MunMU nounoruaad
(OEl eeerdiaaiei •toeft *>oTbe tit Office of
Haardoui Muchalt Kcpilaaoo Latd nti
nacmitf Color Totcnaa Chant ID Tabta 1
•ad 2. aad iht CIE eoor*naie (ot UK eotor
loimaeB **al*A a Table J. Oenl oaten
asd Kjtcrwwe oocnbrJ in Table 2 apprwb-
•Be ihoae docribcti IB Table 1 vtaik ajlowiai
for tiHtmcB » production isehodi ud
•aiehalt BMC] to mamifaaurt labeii ao£
piaearti •rfaecd vtih pnmini tnki. Pnmahry.
Hie colot cttani ba*ed «n Tabi« ! art for labe1
or ptactrt colon applied at opaque coeuuji
wA it pain, •aad a> piuuc.
LOW! 1MB
. 1»J? 0/»_
. I»J»4J'«4.
. i».e^ O'ij_
. W.af I.O/U-
, tt.c^wia-
11.11
HIT
1100
.ttw
JU«
JH)
.IJU
.1111
.III!
IIM
.1*90
J14I
•Mr un 4Mon CTMB tM »umu. ta*
HTTMI «>UBA. TMn'on. Uc ciBunua ctLncw uiuu «' tAMe t*a
TABU L-Soanriotiotu for Color Tofcnact Cham for UM With
Ubdi ud Plaarti SurfMad With lafc
, 19T»,*4FM09»*.
. I9n\
itwrmmimC
. 4JK4J1/U.
. IT* 4Jt/lX
. UK 4.4T/11
. i jut t,
uut
t«J>
U.M
1JJ4
I1JD
JITJ
(AppweJUA)
GMrMcM tafuutten
-------
COMMUNICATIONS
218:0131
T*K{ 2.— Sptf.ficaiions for Color Toiiranct Crtens for Use *'it
Labtis tntl Placards Surfaetd Wit*
ClT8«i» If
f
. _____ ______ T1R4TJ-I1.J ..... .- ........... . I7.«
liv iZToJintf ________ 14«4.M.1:« ----------- It.*
Uint 3* wrwi _______________ « IH 4.7I/ ill -------------- H J»
oUJ" _ ____________________ ».TR4ll'i:S ..... ---------- ISM
' _ ___ I.OK «.». I:.M ------------ u.-n
J»»»
Onnti
Dirt ufi oranit A .................. J.4Y'.)»'I04 ............. «.I6
DvtiMennfiB ..................... 3.5Y 7.41/in.O ............. «».»
aw
UJ»
CtntiJ co-or
GPME tae r*"ii> A.
gsat
Dtn OM nvub.
O*n IB* tvrvii A.
Dtn to* MUM* B-
CmnlwMC
.4J»«
aiw
.4JW
•«*«
J«i
J»*4
1U9 J»U
toi
u.W
JIM
jjrt
uni.t4'i.i
tepB 4« n
LTTB 4J).'I.O
i.miJi/i.7
4.TFB JAJ/1C C
ura i.n/ij
, Lnraua/tu
, tTJI 4Jl/tJ
I44I/IJ
IUI/IU4
I 4.11 /I.I
. 4Jra i.rr/tj
, UPBLM/t*
.w
JIU
JBtl
JOM
4iJ7
JWJ
OtJl
JU1
jr.
J>«4
jrrt
»ST«
by THE »U«AU OF NATIONAL AFTAHtS. WC., WASHINGTON. B.C. JOOJT
lift]
-------
215:0132
HAZARDOUS MATERIALS TRANSPORTATION
TAILS 3.-Jp*rt/leo*ionJe' Colon for Vit Wit* tcbcU ^inud on •ocJkflffir.oi Surfaces
|44 FR 97J6, February 15, 1979; 44 FR 109&4, February 26, 19791
C1I oau (or tour
T'lr- '
n C KP« C
,,,
it*
: : , "'
4J*
"'
MO
• 1
>fl-4« 1
.4*0
31C
.400
.Mi
J»S
J04
410
41.1
its
r«iiom <
.411
.4*0
.441
Jtt
MO
.44C
.41]
st.i
Srrtn
nt
ow
J10
JK
^0]
J1C
.401
B.I
B.UI r
JOO
J71
JK
.ITI
J*4
JM
jn
UJ
1.1
'unit
j_
jet
J7T
J43
jet
J43
tlJ
IJ
AprcHDix B—DncHitown arccmc*noi<
rot PUCAUI
l. Placard *poeifte«ri0iu. (a) Tbt pnat
*Tp* on *ecb placard muit bt ptaakliB Ootalc
Ceodtawe.
(b) Caeb aquArt-ca-Botat placard man
Btarort lot; tacbt* (2TJ.O ma.) on aca
no*, tbt outer. H-IBCA (U.T ma.) of vaicb
Boat bt wait*.
Xen: Tb« aaarunmtau la tn*t* tptci-
acaUoni Bar b* rouao*d te tbt a*aron 1/12
e; «a tacb aad te vbt atanat vbelt mUli-
att*r.
outrr 4 >IDC&
(13.7 am.) wtiu placard boratr. Tb« plac-
ard color mart b* raa. woiu. tad bltck.
(ji IZHOSlVtS A iliefrt. Tat wort
•BEn>OBTXS" mu*t b* taw Vbt etaur
an* ol tai pUetrfl ud atdt witt tatun
aa.)
aookt Tbt top ot tbt Itrcan la
(U.I mm.I abort tbi placard boruoaial oaa-
ur Unt Tbt top at tbt Ittur "A" BUI; bo
If.lacfl (i3.7 sa.) b*io« tbt boruoatal
oaaur Unt. Tbt l*tut -A" mm b* tppreu-
mtttlT l tacboi (MJ mm.) bl«b. Tb* bait of
tbt rrmbol mon bt JUi menu «2.t am.)
•aae*t tat plaeard aortBoaial etnttr lint, aad
B\ui bt «H tacb (114.4 am.i bl(b wa*a
BtarurM trcm a beruoaul Uai toucbiaf tbt
aowott cnraaitr. Tbt vidta of tbt
suit bt T\ iBcbt* (200.0 mm i wbta
ar*a otcwto nro lintt parptadicular te ibt
km** Uat tad tooehlac tbi wtdtat
•a *aeb aid*. Tb* rmdlua of tb* beat Bon bo
t't-iacb (itA mm.). Tb* plaeard eolot mutt
bt enai*. buck, tad waiu.
(1) Ezetpt lor U>t utur f. tb* BE-
•LOema » placwd ipaeinottioai ar* tb*
OBCM at tbo*t for tb* ZDMSrvxa A placard.
Tb* locaoaa. aetgbt. tad nrokt tor la* Utur
-»- an tfct oaat aa tboa* cnoenbod for ta*
WtUT "A".
(4) Tb* word -KOK-PLAiOUKJr But
i tb* oanur am wit* tb* wora -OAA-
alb' tb* word *XOH.PUal-
•Ta» lotun ta betb wordi mrart a»
i (WJ am.) alfb tad aad* vttb ft
•tflaea (7J am.) ftraki. Tbt top d taa
latun la tb* wordi -HOK-Tt *mifHT,r-
aan b* IH tacbo* (UJ am.) abet* tb*
placard aonaecuJ otaur lint, aad tbt top of
ta* l*tun IB tbt word *OA5" mun bt »u-
tacn r 1O am.) bale* tbt plaeard benaaatal
oaaur Ua*. Ta* baa* ot tb* ITBBOI aval b*
1M iDcait (TSJ am. I abort u»
emurlut wtta tb« top 4^,t laeha (1SS.4
am.' ftVtvt tbt placard aarucnul «taiu
Hat. Tat lower portion or tat crliaatr (rrm-
bell suit bt iVr-iaci (UJ mm.) widt vtu
tat atcx u >lacb 04 mm.) lcn|. Tbt
placard color au>t at fnta aad «aiu.
(I) Tbt word "OZTOCy auit bt etaund
OB ttt placarti aoruontai e*at*t liat in
Utun 3Vi laeaoi (U.5 am.) al|b and aadt
wile a nflaca (11.1 aa.) rcrok*. Tbt bt**
of tat bar la tat §710601 muit M 3>M laeaa*
(U.t mm.) abort tbt placard benxoeui
oaaur Uat. Tbt ortrall btt(&t of tat trabel
But bt 4iic UOS.J mm.) wita tat bar ata*-
vnrtt H-laea (SJ am.) wtot aad. l*>ctacata
(UJ mm.) leaf
Tbt irabol mun bt :', lachtt (60.3 mm )
tcroa tat wiotn pan.
Tbt ouwr H-tac* (12.7 aa.) of ibt 10 1.
laeau (3T3.0 am.) tquart oo-polat placard
mun bt »aiu Tbt placard color miut bt
ytnow. black, aad vaiu.
(6) rUJtlUMLt CAS flfnri. Tbt morJ
"PLAlOLaBIZ" awi b* acroai tat placard
ctBUi arta wtit tut word "OAS" outaratf
btatatt tci wort TlAkfUaBLf. Tbt Itl-
wn IB beta vorci mu«i bt I meat* (HJ
am.) bifb tad aadi witt a placard oseopt
for cat word -CHLOJCWr tad (M rraboi.
Tat word •CBLOia'X" aon b* otatand oa
tat placard aoruoataJ oaaur Uai la Mtton
IH laeboi (BJ am.) bicb aad aadt wt«a
• ht-iaea (UJ aa.) raoki. Tat lewort
pan et tbt fyabal nnwt bt IK laebt* (44.1
•a.) aaeft tbt placard konagaui ooaur
Uai. Ta* irabol autt bt i>tii laeaoi (H4
aa.) bifh tad (H tacboi (ttca mm.) aorct*
tat -rwltrr ornvainoi
(•) KUSQH a AS plii'ii'*. Tb* ward
fOOOtr- aon a* tent* tbt tutor aroa
of ta* plaeard wita ta* word *OaB* ooa-
•tod boMtb tbt word TpUOrT.* Tbt tat-.
un-ta botb word! aun bt a»« lacaw)
(UJ am.) bl(b tad aadt vitb* 'Hi tnrn
(10J am. I mo**. Tbt top of at utun ia
Ibt word TOIBOK- aim bt lu lacaoi
am.) abovi tat bonioatal oaator Uai. Tb*
lo»att part of tbt armaol aon b* I*, tacbai
(•JJ mm.) taovt ta* bonaoatal eoaur Unt
CrtomieaJ Nvgulattan Mtvorur
•ao-auit bt Stt lacbn (ts.i am.) tlfh ana
«iu tad)** (108.5 BB.I aeroti tbt widan
•nnatuaa. Tb* >.*-iacb (JJ aa.) black
borotr aun b* H-iacb (li.7 am.) la from
tbt placard adft. Tbt plaeard color mutt b*
black aao, wait*.
(I) ruutHAILt pttetrt. Tb* word
•PUlOiABLZ" mutt bt otatarto oa tbt
plaeard aonaonul ctaur llat Tbt litttn
la tbt word "fL*>tUABLZ' muit bt 2 taebt*
(Hj aa.) bifb ana aadt witb aa "te-
lnet (1.7 mm.) ftrokt. Tat baat or ibt trm-
boJ bar mun b* 2^ lacati (17.1 mm.) abort
tbt plaeard aonioataJ etaur Uai. Tbt 1719-
DO) BUI: b* «Si tacba (iUJ am.) wid*
aad iHc lacboi (M.i. Ba) wwt. Tbt bar
suit b* H-iath (>J mm.) widi end J\c
tbcbci b* *aiu.
(10) EMPTY placard. The ipeeificinani
for tht FLAMMABL£-EWm' pl.cmrd u
fcpraimirive of the requirement! for th«
fbllowini EMPTY plaiardi: NON-FLAMMA-
BLE CAS: POISON CAS; CHLORINE:
OXYGEN: FLAMMABLE CAS: FLAM-
MABLE: FLAMMABLE SOI ID: FLAM-
MABLE SOLID W: OXIOIZ£K ORGANIC
PEROXIDE: POISON, and CORROSIVE.
Tht ipteificanon for aart EMPTY plaeard
nun be the umt u tnotc pracritwd for each
plaord txerpt for the top tnanflt in the
piacarti.
. Tb* bat* of tbi black tnanflt auit bt
U-iacB (ta am.) abort tbt te; of tb*
Utun la tat placard baat.Tai ban of tb*
Ittun IB tai word DaTTT aun b* IK
tacbot (BJ am.) abort tb* placard ben-
•BtaloaataTlla*
Tb* tooon u tat word TBtril' aran b*
(•iacfi (U.4 mm.) ai«a tad aadt wiu a
Hi tatb (U mm.) toot*.
Tb* DCTTT placard* may k* aadt la
aar ef a* tarn wari dud la 1172*«(ei.
•obpan r off Pan 173.
(11) CQKtVSntlX pUecrtf. Tbt rptelfl-
oaOoa for tbt COiaVaTIKZ placard an
tat aant a* taooa Bia«.iiuiii for tb* 7LAM-
atlBLJt planoffl taetpt tai Icttan IB ta*
word -COUSUIllaLl- aun b* l% taebaa
(47J am.) bj(b aad aao* witt ta "fe-iaeb
(«.7a«a.) oerokt.
(U) njOtHAtir tOUS »laeanl. Tb*
of ta* placard wltb OM word *SOLZDr
awt bt I inrtiB (M J) •
vua ft H-taeb (U BB.)
la ta*'word •MUD* *ntt b* IV
fBU am.) bl|b aad aad* witb •
) aicb tad aadi
~
(CJ am.) wvoka. Ta* top ot tbt Utun
la tb* word "^ -""•"— aun b*
•r tb* rrabel bar aun bt IK b»ca*» (174
-------
COMMUNICATIONS
9938 2
RAI-U
215:0133
ma. I Men tb* pueirt -acmes uJ **B««T
lint. Tbt FfBbol muii bt »»i« ibcbt* illJJ
•&.) but kod 9*i< incb»t iM.: am.) »id«.
Tbt ouur ri-mca (in aa.) « tb* '"V*
iBCli** 197} 0 BIB.) •S.Ukn-OB-pelBt pLMkrt
BUIK b* wait* »—>• rM tea wbiu imp*
Ban b* kpprexinut*!; 1 tccb (U.4 BO-)
*Ut. Tb» pjtcvti »u»t b»»t MTU no itnpo
kBfl Bi wbit* rmptt Ont r*a nnp« man b*
•ppraaakmy o*nt«r»d en tb* veruail tester
luu ai (b* plke*r6 Tb« plkekre eclat mu*t M
bun*. wait*. ted r*«.
(IS) rLJiH M AMU SOUS » ptae*>*. Tbt
•pecttetBaa* tor tb* n^UUAILZ Vlf TT) W
•re tbt Mat M tit fceeSBCkUeu (or tbt
njLUUJLB^I fi'Ti pikckra exotpi tor tb*
tee vrUAfit. Tbt but ctf tbt blot oua(lt
Bun b* 3 tacit* (M.I mm.) kbort tbt
plfcsue boruwtuJ oeaur liot witb tb* but
«• 'tb* fTBbel m incett i«j BB ) •Aon
tbt pltewtf boruoBtAl etour llu Tbt tra-
kal arut bt at inthti (S'.i BB.) hl|&;
3% inebM («J BB.) teen tot top 1%
ttteb« <*».« BB.) t0ou tbt bMt. tee m*4t
•no t HfUtt HJ am.) nrou. •»* wtiu
•mpt IB tht irmbal BU*I b* \kt mcB ttJ
BOL i vtt* aus »H taebv (U> BB. ) leaf.
Tbn vbtu imp* Bun tuct vpw« traa
B«!>t to left M u «aclt or approaauwlj 31
tuimi troai tu bauaat^l. Ttta pticart
•uy b* BMt tc *cr of ut i&r*t v*r< ciwti
at I iTa>M. nBpvt r of r*n ITJ.
(Ml OflBJtI» pltrfffl Tb» wore -OX-
Ban bt ouiwr*a OB Ib*
aut« Unt IB Ittun as
Bcbti (*04 ma.) vitb «a
BB.) icratt. Tbt le*tr tdp el tbt ytuow
oik&fI* mun bt lit ioca«t (34 g BB.I ttwt
tbt pwckra Borueetki otnt*r un*. T&i lowir
' •«(« el tb* irate) Bun bt lv> iscbti (11.7
am.] kbott t&t plkare hemaauJ etatu
Uu. Ttt fTBbo! a\i(t bt BU« u SBOVB
vitb tbi toUoviBi ttBiaaioBi:
3-4 in MM.
Tbt levtr »bJlt kne, Bon b»»t k
(13 BB.) bl«e» esua UB* bcratr
from tb* *Aft oJ tbt rtlle* km to
BAle»t*
tbr ouwr H-uee (13.7 am.) wMt* plkesrd
borotr Tbt pl»ckrt coin auii Ot y.jiew
buck. *na wtiiu.
(Ill COXffOSlvc plonrd Th« word
"COIUlOSnT" aufi o* kcract tb< e*Bi*r at
tbt plkctrd kba Bad* *iu Ittun 3-*i.
iBCBt* (ta.« BB.) UCB viu k "—-loch
((* mm ) icrolt Tb* b*** el tti lop wait*
tn*Afl* Bun M 1H tbcbet (M.I BB.1 kbevt
tbt puekrt boruontu eesur UM. Tb* lev-
Mi p*n of tb* rrnbc: Butt b* l>i l&cbet
1*1 J BB.) kbe** tbt plkCkia boruonui etc-
Mr IB*. Tb* b*ifbt ol tb* (TBbol OHMUTM
from k bonnatkl UB* «n*na*l trcm tb*
leviet pu% at tb* rrmbol aun bt JVi ucbei
(S34 BB. ) k»a tbt v)OU> kcroki tbt vio»t
p«n aun b* 1% bMbet (1174 BBV). Tbt
oppvr »BJU *r»» aun b*«t k H-iecb (S.5
BB.) Bite* toaa Ub* boroir k* kB uuniion
trea tbt Mp of tb* buck WM va
tb* ouur Vt-lMb I ll' BO. I vbiu
bgrttr. Tbt pUevri oMor muf bt M*ek kkd
(19) lUSTSKC ACDfTS ftmmi. Tbt vardt
ILAJTTNC ACHXTJ mua kt *oro B« omur
tru ot Ui pl«an we BUI >n> kmtn !•"»
[47.* •URikiffcrnftti/lc-MB (?.*••> •ntt.
(U FK STPir Dtemtxr II. 1*71)
APPENDIX C-OIMENSIONAL SPECIFICATIONS FOR RECOMMENDED
•PLACARD HOLDER
tbl
tt Tbt but aT 161 b*r ar ttt
bt 3V>i^tDObM (U.4 BB.)
rt bnuosul ouur UM. Tbt
or tot rrmaoi ttur. M 4^11 iacb«
(KPtJ BB.) *lboTt tb* ptkeue ban-
emtir Uc». *co ttt top o? tbt IVCMH
wtmu TiaoCDr; ao«t bt Mr
B.) k*)o» tb* plMUti barcocul
ua«. Tnt bMt of ttw frsboi bu BUM
bt 3% isebM (Tt.o BB.) «bo*« tbi bonarB-
«1 ((bur Us*. Tbt irmbol Btvt to tutt
(HJ BB.) UCB ud >Ki IBCOM (13 J
.) viflt'witb tbt btr KCIBCB («-« BBV)
tad 1% laebM |47.( BB.) toa|. Tb*
•imr H^ata (ill BB.) oi tb* 10%, wcb*t
.I
i vftlu. Ttt
cola Bun b* 7«UB«,
(tt) fOtSOH pUtvt. T»*
B«t bt •nund ee tb* plkcue ban-
««Bt*r Un* IB Ittun IHi taeb*>
BB.) hlfb kb« BMt «ttt • lit-lBCb
BB.)
tIM r' ---
•01 man
M« «Hti
bt >H tbcb*t (MjO BB.)
jorMbBtM •nur UM. TM *T»-
(m( main IMJ BB.) H«&
(UI4 BB.) •OWI tt*
n* H>B«b (U BB.)
bi Vi>i«b (U.1 BB.) ta
(17)
*iUDio*cnvr~ aon
BMJ CbBUT
Tb*
[41 FR 42433. September r. 1976]
IMMC
Pteblikh.d r/ THE IUII£AU OP NATIONAL ArTAOU, WC., VASKWCTON. D.C. 1003?
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> SS'58.2
TABLE OF CONTENTS
Page
I. Introduction i"1
A. Objectives of the Act I"l
B. Role of Inspections in the Enforcement
Program I~3
C. Purpose of the Manual..: I'4
D. Audience of the Manual .' I"5
E. Structure of the Manual I'6
F. Updating the Manual 1-6
II. Safety Considerations H"l
A. Objectives II"!
B. Responsibility of the Inspector II-l
C. Types of Exposure to Hazardous Waste II-2
D. Initial Hazard Assessment H'4
E. Safety Equipment H"8
F. Emergency Treatment 11-17
G. Long Term Risk 11-20
H. Decontamination and Disposal of
Protective Clothing 11-20
I. Safe Handling of Hazardous Waste 11-22
J. Other References 11-23
III. Administrative Procedures III-l
A. Work Ethics HI-1
B. Disclosure of Official Information III-4
IV. Preparation for Inspection IV-1
A. Objectives IV-1
B. Responsibility of Inspector IV-1
C. Administrative Preparation IV-2
D. Notification IV-4
E. Inspection Equipment IV-5
V. Conducting the Inspection V-l
A. Scope of Inspection V-l
B. Entry into a Facility V-2
C. Pre-Inspection Discussion V-5
D. Record Review V-7
E. General Procedures V-9
F. Sampling V-13
G. Packaging, Labeling, and Shipping v-34
H. Quality Assurance J-41
I. Documentati on ""43
7/24/81 RCRA INSPECTION MANUAL
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Revision of 1981 RCRA Inspection Manual
Agenda for Workgroup Meeting January 21-22, 1987
Wednesday January 21, 1987
10:00 AM intention of workgroup meeting
10:15 Discussion and review of the 1981 Manual
-Usefullness of the current manual
-Purpose of the manual (Is it being realized?)-'
-What are the major problems concerned with it?
11:00 intended audience of the manual
-Who should be using this manual?
-Affect on guidance development
12:00 Lunch
1:00PM Format/Organization/Style
-Affects of the intended audience
-Relationship to the purpose of the manual
2:30 Break
2:45 Content of the Manual
-Keeping in mind the previous dicussions, what
will need to be included and what can be removed
-Affects of established and proposed guidances
Out by 5:00
Thursday January 22, 1987
6:30AM Brief review of Wednesday's discussion
ci:oo New comments regarding material covered on Wednesday
10:00 Break
10:15 Continuation of discussion on the manual's content
12:00 Lunch
1:00 Wrap-up and summary
Out by 2:OOPM
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