AuditsCompliance-in-a-Box: The Startup Guide to Audit-Ready DocsSVSid Varma · 12 min readFor EHS managers at large and small quantity generators who keep the contingency plan, quick reference guide, job descriptions and training records a state or EPA inspector reviews.
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Checked against primary sources on 18 October 2026.
Sites that generate hazardous waste: large quantity generators carry the written contingency plan and documented training duties, while small quantity generators meet lighter emergency and training conditions.
Authorized state environmental agency inspectors and EPA regional inspectors
No fixed inspection cycle; large quantity generators file a biennial report by March 1 of each even-numbered year and staff take part in an annual training review
40 CFR Part 262 as amended; 262.16 and 262.17 last amended effective March 21, 2025 (technical corrections, 89 FR 99727); Subpart M unchanged since May 30, 2017, 2025-03-21. Free to read.
| Date | What happens | Status |
|---|---|---|
| 2025-01-22 | e-Manifest third rule takes effect | Done |
| 2025-03-21 | Generator Improvements Rule technical corrections take effect after a delay from February 10 | Done |
| 2025-12-01 | e-Manifest third rule compliance date: export manifests and exception, discrepancy and unmanifested waste reports move into e-Manifest | Done |
| 2026-03-01 | Biennial report due for 2025 large quantity generator activity | Done |
| 2026-05-04 | Comments closed on EPA's proposed Paper Manifest Sunset Rule | Done |
| 2028-03-01 | Next biennial report due, covering 2027 activity | Scheduled |
Each one needs an owner, an approval, and proof it reached the people it covers.
40 CFR 262.260, 262.261
Describes what personnel do for fires, explosions and releases, with arrangements agreed with local responders, emergency coordinators, emergency equipment and an evacuation plan.
40 CFR 262.262
The plan and every revision stay at the site and go to local police, fire, hospitals and response teams, with a quick reference guide when first required or amended.
40 CFR 262.263
The plan is reviewed and amended when regulations change, the plan fails, the facility changes materially, or the coordinator or equipment lists change.
40 CFR 262.17(a)(7)(i), (iv)(C)
A program directed by a person trained in hazardous waste management, covering procedures and contingency plan implementation, with a written description of introductory and continuing training per position.
40 CFR 262.17(a)(7)(iv)(A), (B), (D), (v)
Each hazardous waste job title with the employee's name, a written job description, and records of completed training, kept for current staff and three years after departure.
40 CFR 262.16(b)(9)
SQGs name an emergency coordinator, post the coordinator, equipment locations and fire department number near phones, and ensure employees know waste handling and emergency procedures.
Citations are to the standard or regulation; wording is ours.
What reviewers sample about these documents and the people they cover.
The plan and all revisions are kept at the generator, so inspectors can ask for the current version and evidence that it and the quick reference guide reached local responders.
LQGs maintain each hazardous waste job title with the named employee, a job description, the training description and records of completed training, so the roster can be traced end to end.
New or reassigned staff complete training within six months and do not work unsupervised until they do; all facility personnel take part in an annual review.
Evidence of weekly inspections of central accumulation areas, and the biennial report on EPA Form 8700-13 A/B filed by March 1 of each even-numbered year.
Write each policy, send it through approval, and send it to the people it covers. Each acknowledgment is recorded by name, with the version, the date and the time.
When a policy changes, the new version is approved, its Editor sends it out again, and everyone it applies to is asked again. Export the record as a PDF or CSV, or give a reviewer Viewer access to the documents their tags allow.
Need help with the rest of EPA RCRA hazardous waste generators? Find a consultant for your standard (opens in a new tab).
Your region’s laws, the standards your customers ask for, and your own house rules. Write each one as a policy, approve it, and send it to the people it covers.
Yes. A generator with an SPCC plan or another emergency plan may amend it to add the hazardous waste provisions, and EPA recommends basing a combined plan on the National Response Team's Integrated Contingency Plan guidance.
For employees trained under 29 CFR 1910.120(p)(8) and (q), the large quantity generator need not provide separate emergency response training. The overall facility training still has to meet every 262.17 condition.
Records for current personnel are kept until the facility closes, and records for former employees for at least three years from the date they last worked there. Records may move with personnel transferred within the same company.
Since May 30, 2017, large quantity generator contingency plan requirements sit in Part 262 Subpart M, referenced from 262.17(a)(6). Part 265 Subpart D remains the interim status rule for treatment, storage and disposal facilities.
Yes. EPA notes that certain states have additional or more stringent requirements, so the authorized state program sets the text an inspector applies.
Industries that hear about EPA RCRA hazardous waste generators most.
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