The following is designed to provide business owners an understanding of what to expect during a Small Quantity Generator (SQG) inspection:
- Typically, an SQG inspection is performed unannounced.
- On site, inspectors will ask to meet with the facility owner or manager.
- A review of all waste disposal receipts for the last 3 years will be performed. This is to help determine the generator status of the facility. As a generator status and waste volume increases, more requirements apply.
- A review of Material Safety Data Sheets (MSDS) and any laboratory analyses will also be performed. These will assist the facility owner to determine which wastes are hazardous or non-hazardous and how to properly manage them.
- A complete inspection of the facility, including any outside areas, will be conducted, in conjunction with the facility owner or manager. The inspector will look at the operations of the facility, the chemicals used, how wastes are stored and where. Questions related to the above will be asked to clarify how the facility operates. It is expected that the facility owner or manager will be completely honest with how the facility operates, so the inspector has a true understanding of what is going on and can advise the owner or manager accordingly.
- The inspector will also advise the owner or manager of other government regulations that may apply. Depending on the level of concern, it may be necessary to refer it to the appropriate agency for further investigation.
- Based on the inspection and the information provided, non-compliance issues or potential problems will be listed on a Hazardous Waste Inspection Report which is left with the owner at the time of the inspection or in a letter sent after the fact. The inspector will advise the owner of any corrective actions that need to be preformed and the time frame for completing them.
- Depending on the corrective actions that are suggested, a reinspection of the facility may be necessary. If not, communication through telephone conversations and/or emails will suffice to resolve the issues.
- While SQG inspections are designed to be educational and may provide cost savings, they are still regulatory in nature. Therefore, cooperating with the inspector and correcting any listed concerns are the keys to a cooperative and successful inspection.