RCRA Recordkeeping Requirements for Waste Generators

Proper recordkeeping is the backbone of compliance under the Resource Conservation and Recovery Act (RCRA). Whether your facility produces 2, 200, or 2,200+ pounds of hazardous waste, your records are proof that waste is being identified correctly, stored safely, transported properly, and ultimately disposed of in line with the law. When those records are incomplete or missing, it can result in steep fines, legal headaches, and even environmental harm.

Why Recordkeeping Matters

RCRA is the federal law that governs how hazardous and non-hazardous wastes are managed from “cradle to grave.” In other words, it covers every step of the process, from the moment waste is generated to its final disposal. For generators, proper documentation is essential. It demonstrates compliance, prepares you for inspections, and shows that you take environmental stewardship seriously.

The stakes are high. Poor recordkeeping can lead to citations, civil and criminal penalties, or long and costly enforcement actions. It can also undermine your credibility with regulators, customers, and the public.

Know Your Generator Status

Not every facility has the same recordkeeping obligations. The requirements depend on your generator status, which is determined by the amount of hazardous waste you produce each month:

• Very Small Quantity Generators (VSQGs) produce no more than 220 pounds of hazardous waste in a month.
• Small Quantity Generators (SQGs) produce between 220 and 2,200 pounds.
• Large Quantity Generators (LQGs) produce 2,200 pounds or more.

The higher your generator status, the more detailed and frequent your recordkeeping requirements become. Understanding your category is critical because it determines how often inspections are conducted, the types of reports you must submit, and the retention timelines for your documents.

What Exactly Is Required?

For hazardous waste generators, the Uniform Hazardous Waste Manifest (commonly referred to as “Manifest”) is one of the most important documents. This form tracks waste from the generator facility to the disposal site, and generators must keep signed copies for at least three years.

Land Disposal Restriction (LDR) notifications are another key document, required whenever hazardous waste is sent to a treatment, storage, or disposal facility (TSDF). These also need to be kept for at least three years.

Inspection logs are also required, with LQGs needing to conduct and document weekly inspections of hazardous waste storage areas, and SQGs doing so monthly.

Training records (covering initial and refresher training for employees who handle hazardous waste) must be kept for at least three years from the training date.

Waste determination documentation, whether based on analytical testing or process knowledge, should be retained for at least three years after the waste is last sent off-site. If you’re an LQG, biennial reports must be submitted every other year and kept for three years from the due date.

Even if your facility only handles non-hazardous waste, it’s smart to maintain disposal documentation, such as waste profiles, recycling receipts, or landfill scale tickets. Some states and localities require these records by law, and even where they don’t, having them on file demonstrates diligence.

Requirements at a Glance

Here’s a quick reference table to help you compare requirements across generator categories:

Avoid Common Pitfalls and Build a Strong Recordkeeping System

Common RCRA recordkeeping mistakes include missing signatures or dates on manifests, skipping required inspections, letting training records lapse, and keeping files in multiple locations. Some generators also overlook renewing waste determinations or rely only on paper records that can be lost or damaged.

For LQGs and SQGs, a newer challenge is the e-Manifest system requirement. On January 22, 2025, the EPA passed a new requirement that LQGs and SQGs must create and maintain an account with the e-manifest system. Generators may still use paper manifests, but TSDFs no longer need to mail back physical return manifests; instead, the completed manifest might be uploaded to your account. If you’re not logging in regularly, you could miss these critical documents.

Avoiding these deficiencies starts with a centralized and consistent recordkeeping system. Keep records in one place, scan paper copies, and review documentation at least annually. Using checklists to track inspections and proper waste management can also be very helpful. Lastly, don’t forget to train your staff on proper waste handling and recordkeeping procedures.

How Walden Can Help

Strong RCRA Recordkeeping Requirements for Waste Generators compliance isn’t just about avoiding penalties. It’s a signal to regulators, customers, and your community that you take environmental compliance seriously. By keeping organized, accurate records, you protect your business, your employees, and the environment.

If you’re not sure that your records are compliant, Walden can help you close the gaps. We work with facilities to conduct internal audits, verify generator status, create customized checklists, and implement practical systems for organizing and retaining records. We can also assist with inspection preparation and provide ongoing compliance support, so your facility stays ready year-round. Contact us at 516-559-6976 to get started today.