RCRA - RECORDKEEPING > Overview

In most cases, individual laboratories within schools or universities will set up satellite accumulation areas for the hazardous waste they generate and transfer the waste to a central hazardous waste accumulation area when waste containers become full. More information on container management in Satellite Accumulation Areas can be found in the Satellite Accumulation Area section of the EVC.

Schools and universities that ship hazardous waste directly to a permitted treatment, storage or disposal facility (TSDF) must comply with strict administrative and recordkeeping requirements of the Resource Conservation and Recovery Act (RCRA). All facilities that ship hazardous waste must ensure the waste is properly transported and disposed of.

This section of the EVC will address shipping and record keeping requirements under RCRA. The expanded content that is provided includes in-depth descriptions of what is required while this brief content is intended as a summary.

Depending on the hazardous waste generator status of the school or university [Large Quantity Generators (LQGs), Small Quantity Generators (SQGs) or Conditionally Exempt Small Quantity Generators (CESQGs)], the facility may be required to have the following:

• EPA Identification Numbers (SQG and LQG facilities)
• Manifests, including documentation that the waste shipment was received and disposed/treated at the waste facility (SQG and LQG facilities only)
• Source reduction strategy and the ability to sign a manifest stating such
• Biennial Reports (LQG facilities only)
• Copies of Waste Analysis to document proper hazardous waste identification
• Certification of Land Disposal Restriction (LDR) Notification with Manifests

Continue on through this EVC section to learn more about record keeping requirements of RCRA.