These figures are dated and partial. There is no official national top-10 list of hazardous waste generator violations. National figures come from EPA's Hazardous Waste Determination Program Evaluation, Final Report (April 2013), which analyzed inspection records in EPA's RCRAInfo database; EPA has not published a newer national figure we could verify. Ranked counts come from one state: the Montana DEQ Hazardous Waste Newsletter, Issue 5 (June 17, 2025), covering 5/14/2022 to 5/14/2025. Texas TCEQ's Dallas–Fort Worth region publishes an unranked, undated list of common issues that matches the same pattern. Your state's results will differ. * Rows marked with an asterisk are EHS Concepts calculations from the published figures.
-
Waste determination: deciding what the waste is
- 2x waste-determination violations versus any other RCRA violation type (EPA, 2008–2009 data)
- 34% national non-compliance rate for the determination rules in EPA-led inspections
- 36 Montana citations for failure to determine if a waste is hazardous (No. 6)
Start here: Walk the site with a clipboard this week and list every waste you make. Pull the SDS for each source chemical. Ask your waste vendor for the profiles they have on file and compare.
Rules and guidance: 40 CFR 262.11 [EPA] · Part 261 [EPA]
-
Hazardous waste labels and hazard marking
- 75 Montana citations for a missing indication of hazards, its No. 1 violation
- 48 Montana citations for a missing hazardous waste label (No. 3)
- 123 labeling citations from those two items alone, about 31% of all 403*
Start here: Buy a roll of pre-printed hazardous waste labels with hazard check boxes this week. Label every container on site in one sweep.
Rules and guidance: 40 CFR 262.15(a)(5), 262.16(b)(6), 262.17(a)(5) [EPA] · 1910.1200 [GI]
-
Accumulation start dates and time limits
- 37 Montana citations for a missing hazardous waste accumulation start date (No. 5)
- 180 days an SQG may accumulate waste (270 if the receiving facility is 200 miles or more away)
- 14 Montana citations for LQGs holding waste longer than 90 days (No. 10)
Start here: Put a whiteboard on the waste cage: container, start date, ship-by date. Book the next pickup at least 30 days before the oldest ship-by date.
Rules and guidance: 40 CFR 262.16(b)(1)–(b)(6), 262.17(a) [EPA]
-
Closed containers and weekly inspections
- No. 1 issue on TCEQ DFW's common-issues list: no weekly inspection of container storage
- No. 3 on the same list: containers left open when not adding or removing waste
- 24 Montana citations for open universal waste lamp containers (No. 9)
Start here: Buy a latching drum funnel for every active liquid waste drum. Tape the weekly checklist to the cage door and put the inspection on the supervisor's calendar.
Rules and guidance: 40 CFR 262.15(a)(4), 262.16(b)(2) [EPA]
-
Satellite accumulation areas
- 55 gal maximum non-acute hazardous waste in a satellite area (1 quart liquid or 1 kg solid acute)
- 3 days consecutive calendar days to move or properly manage any excess
- 2016 year EPA's Generator Improvements Rule rewrote the satellite rules (published Nov. 28, 2016)
Start here: Put a laminated card at each satellite station: what goes in, the 55-gallon limit, “date it and call [owner] when full.”
Rules and guidance: 40 CFR 262.15 [EPA]
-
Emergency preparedness and training
- 44 Montana citations for emergency preparedness violations, its No. 4 violation
- 3 items an SQG must post next to telephones or in waste areas
- 90 days for new hazmat employees to complete DOT training (then every 3 years)
Start here: Update the emergency posting today. Restock the spill kit and add a checklist inside the lid. Invite the fire department for a 30-minute walk-through.
Rules and guidance: 40 CFR 262.16(b)(8)–(9) [EPA] · 49 CFR 172.704 [DOT] · 1910.120 [GI]
-
Universal waste and used oil
- 66 Montana citations for a missing accumulation start date on universal waste, its No. 2 violation
- 36 Montana citations for a missing “Used Oil” label (No. 7)
- 1 year maximum time a small quantity handler may accumulate universal waste
Start here: Buy one lidded lamp box, one battery pail, and a roll of labels. Mark the used oil tote today. Write the start date on each container now.
Rules and guidance: 40 CFR Part 273, Subpart B [EPA] · 40 CFR 279.22 [EPA]
-
Manifests, records, and notifications
- 60 days for an SQG to receive the signed manifest back before it must file an exception report
- 3 years minimum retention for manifests and waste determination records
- 2029 next SQG re-notification year, due by Sept. 1*
Start here: Start a one-page shipment log today: date shipped, manifest number, date signed copy received. Check it on the first of every month.
Rules and guidance: 40 CFR 262.18, 262.20, 262.40, 262.42(b), 262.44, 268.7 [EPA] · 49 CFR 172.704 [DOT]
The full PDF adds, for each item, why it really happens, the rules in plain words, controls in hierarchy order, a 30-minute self-audit, who owns it and a toolbox talk starter.