Mastering RCRA 262.16 Compliance: A Hazardous Waste Labeling Checklist for Airports

At airports, the hustle and bustle can make managing hazardous waste a complex task. Yet, compliance with the Resource Conservation and Recovery Act (RCRA) Section 262.16 is non-negotiable. This checklist is designed to streamline your hazardous waste labeling process, ensuring your operations remain both safe and compliant.

Understanding RCRA 262.16

Before diving into the checklist, it's essential to grasp what RCRA 262.16 entails. This regulation mandates specific labeling for containers and tanks storing hazardous waste. The goal is to ensure that anyone handling these materials understands their contents and hazards, facilitating safe management and disposal.

Hazardous Waste Labeling Checklist

• Identify Hazardous Waste: Begin by identifying all waste streams at your airport that meet the RCRA definition of hazardous waste. This includes substances like used solvents, batteries, and certain types of oils.
• Labeling Requirements: Ensure every container and tank is labeled with the words 'Hazardous Waste', the accumulation start date, and a description of the waste's hazards. Labels must be legible and securely attached.
• Container Management: Keep containers closed except when adding or removing waste. Inspect containers regularly for leaks or damage, and ensure they're stored in a safe, designated area.
• Training: Train all employees involved in handling hazardous waste on proper labeling and management procedures. Document this training as per OSHA and EPA requirements.
• Record Keeping: Maintain detailed records of your hazardous waste labeling and management activities. This documentation is crucial for audits and compliance checks.
• Regular Audits: Conduct internal audits to ensure ongoing compliance with RCRA 262.16. Use these audits to identify and rectify any non-compliance issues promptly.

Implementing the Checklist

Implementing this checklist involves more than just checking boxes. It's about integrating these practices into your airport's daily operations. For instance, I've worked with airports where we've set up routine checks during shift changes to ensure all containers are properly labeled and sealed. This proactive approach not only keeps us compliant but also fosters a culture of safety among the staff.

Based on available research, the effectiveness of these measures can vary depending on the size of the airport and the volume of hazardous waste generated. However, individual results may vary, and it's crucial to tailor these practices to your specific operational needs.

Additional Resources

For further guidance on RCRA compliance, consider consulting resources from the Environmental Protection Agency (EPA) or the Occupational Safety and Health Administration (OSHA). These organizations offer detailed guidelines and updates on regulatory requirements that can help refine your hazardous waste management program.