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Common Storage Violations and Practical Compliance Options

Ramsey County inspection staff enforce the same hazardous waste generator regulations that apply state wide. The most common violations inspectors see are easily and inexpensively corrected.

The two most common compliance violations are open and unlabeled hazardous waste storage containers. Whether the waste is fully regulated or an exempt hazardous waste, all must be stored in a closed container and labeled to identify the contents. Fully regulated waste accumulation must also have an accumulation start date on the label.

A closed container means covers are in place and latched, bungs in place and funnels closed and secured. There are few exceptions: Containers will be open when you are adding or removing waste (i.e. pumping it out). But when you are done, the container must be closed. You may also drain used oil filters overnight in an open container tray. Filters must be placed into the container and that container must be closed when you arrive the next day.

If a container is accumulating fully regulated hazardous waste, then label as such and provide both a descriptive name for the contents and the date you began accumulation in the container. 

For exempt hazardous wastes (such as used oil, used oil filters, used oil contaminated absorbents or universal hazardous waste), the label for each container must describe the waste inside.  For example, some descriptions could include “used oil”, “used oil filters”, “used oil absorbents," “lithium batteries”, “nicad batteries."

It may take time for your staff to adapt to these changes. You might need to follow-up to ensure your instructions are followed. You may also discover your business has containers that are not easy to use, close or label. If staff are struggling with keeping containers in compliance, find out why and then check with your vendor or use our vendor list for containers. In some cases, you might request a container that has a levered lid for rags or used oil filters. This type of container lid makes it easier to open and close your container, and saves time.  You increase the likelihood of employees maintaining proper storage conditions if you make it easier to do so. 

Please contact your inspector if you have questions or need additional resources.

If you need to find a container replacement, please see our vendor list for container and tank providers.

Posted on Wednesday, April 1, 2020 - 3:10 p.m.