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New RCRA Rule: Contingency Plan Quick Reference Guide

Posted on 6/4/2019 by Roger Marks

Hazardous waste contingency plans, whether created as a standalone plan or as part of an integrated contingency plan, play a crucial role in emergency preparedness and response. Contingency plans help ensure that personnel and local responders have accurate, up-to-date information to effectively answer the call and neutralize the threat to workers, the public, and the environment during a hazardous waste emergency. 
 
EPA’s Generator Improvements Rule added many more-stringent requirements for hazardous waste generators.

One new recordkeeping requirement relates to contingency plans and goes above and beyond what was traditionally required for large quantity generators. EPA now requires large quantity generators to create, maintain, and submit a Quick Reference Guide that summarizes the broader contingency plan.
 

8 Items for Contingency Plan Quick Reference Guides


In some ways, the requirements for the quick reference guide are more specific than the contingency plan contents listed at 262.261. The quick reference guide must include: 
 
1, The types or names of hazardous waste in layman’s terms and the hazards associated with each hazardous waste present at any one time (e.g. “toxic paint waste”, “spent ignitable solvent”, “corrosive acid”); 

2. The estimated maximum amount of each hazardous waste that may be present at any time;  

3. Identification of any hazardous waste where exposure would require unique or special treatment by medical or hospital staff;  

4. A map of the facility showing where hazardous wastes are generated, accumulated, and treated - and routes for accessing these wastes;  

5. A street map of the facility in relation to surrounding businesses, schools and residential areas to understand how best to get to the facility and evacuate citizens and workers;  

6. Locations of water supply (e.g. fire hydrant and its flow rate);  

7. The identification of on-site notification systems (e.g. fire alarm that rings off site, smoke alarms); and  

8. The name of the emergency coordinator and the 24/7 emergency response phone number or the number of an emergency coordinator who is continuously on duty.  

(40 CFR 262.262) 

New RCRA Rule: Contingency Plan Quick Reference Guide 

The quick reference guide is required for all new contingency plans and must be added if your existing contingency plan is updated. Whenever you amend your contingency plan in the future, the quick reference guide must be updated as well. Generators must submit their contingency plan, along with the quick reference guide, to local emergency responders like police departments, fire departments, hospitals, and State or local response teams.
 
An incomplete or inadequate contingency plan is a common violation of the RCRA standards. By keeping your contingency plan and quick reference guide complete and up-to-date, you will be better prepared for emergency events and make informed decisions that minimize the risk of a release or other incident.

Get RCRA Trained—When You Want, Where You Want

US EPA requires hazardous waste professionals to complete annual training on the RCRA requirements. Lion makes it easy to meet your RCRA training mandate in a variety of formats—nationwide public workshops, convenient online courses, live webinars, and on-site training.

Browse RCRA training options here to find the course that fits your needs, your schedule, and your learning style.

Want live training? Join us for the RCRA Hazardous Waste Management Workshop near you or train from anywhere with our regularly RCRA Refresher Webinars at Lion.com

Learn more about RCRA training. 
 
 

Tags: contingency plans, emergency preparedness, EPA, hazardous waste management, RCRA

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