No record of the determination

The section is about both

It is titled hazardous waste determination and recordkeeping, and the generator must make an accurate determination in order to ensure wastes are properly managed. The record is how that is demonstrated.

What the record has to carry

What the waste is, where it came from, which route the determination took and what it concluded. If it was made on knowledge, the knowledge; if by testing, the result and the sampling.

And when it was made

Because the determination is tied to the point of generation and has to be revisited when properties may have changed. An undated record cannot show either.

Knowledge-based determinations need their reasoning

Saying the waste is characteristic because the process puts silver in it is a complete thought and it needs to be written as one. The rule names origin, composition, the process and the feedstock as the kinds of thing that count.

A change in the darkroom reopens it

A different film, a different chemistry, a change in how long fixer is used before replacement, or a change in throughput. Each of those can change the waste, and the record is where that becomes visible.

It is a page, not a project

Which is worth saying, because the weight of the regulation makes people assume the paperwork is proportionate to it. One sheet per waste stream, updated when something changes.

And the exclusions step belongs in it

The sequence asks first whether the waste is excluded from regulation at all, then whether it is listed, then whether it exhibits a characteristic. A record that only addresses the third step has skipped two.

The title of the section is the reminder

It is called determination and recordkeeping, and the second word is the one that gets dropped. A determination with no document behind it cannot be shown to have happened at the point of generation.

References