Virtual Flexo Plant

Record Keeping

Description

Keeping complete, organized records is important for a variety of reasons. Some regulations require calculation of emissions based on material consumption. Other regulations require keeping documentation such as hazardous waste manifests and other documents for certain time periods. These documents must be organized and readily acceptable in case they are needed.

Records on usage of materials containing VOC's, HAP's and SARA Title 313 reportable chemicals (see for a list of HAP's & SARA 313 chemicals and SARA 313 PBT chemicals) must be maintained based on a calendar year usage. These records are required to be kept and reviewed regardless of whether the facility exceeded the reporting threshold. The purpose that requirement is to assure annual review of the usage versus the reporting threshold since chemical usage can vary from year to year.

Hazardous waste regulations under the Resource Conservation and Recovery Act (RCRA), require waste generators to maintain records (manifests) of all regulated waste shipments for a minimum of three years. State regulations may require longer retention periods.

Copies of all analytical testing for waste streams and other materials should be retained in the environmental records.

Copies of all operating permits, application forms, and associated reports should be retained for at least five years after the permit has been renewed.

Best Management Practices & Pollution Prevention

Record keeping is an important component of environmental compliance. It is strongly urged that printers keep every record of any purchase, every receipt, or bill of lading. Businesses are required to use a manifest every time any waste, both hazardous and non-hazardous, is disposed. Companies must keep these manifests for at least three years (longer depending on the local/state requirements). A good, well organized record keeping system can help demonstrate compliance and determine the various sources of waste, generation rates, and provide answers for implementing a pollution prevention program.

For access to vendors who may supply alternative materials and equipment, see the PNEAC Vendor Directory.

Environmental Regulations

Records on usage of materials containing VOC's, HAP's and SARA Title 313 reportable chemicals (see for a list of HAP's & SARA 313 chemicals and SARA 313 PBT chemicals) must be maintained based on a calendar year usage. These records are required to be kept and reviewed regardless of whether the facility exceeded the reporting threshold. The purpose that requirement is to assure annual review of the usage versus the reporting threshold since chemical usage can vary from year to year.

Hazardous waste regulations, otherwise known as RCRA, requires waste generators to maintain records of all regulated waste shipments for a minimum of three years. State regulations may be longer. Records that must be kept include the original generator copy and the disposal facility to generator return copy of all hazardous waste manifests, as well as any Land Ban restriction forms completed for waste shipments.

Receipts or manifests for shipments of hazardous materials, empty drums and containers, etc. must be maintained for at least three years according to U.S. DOT requirements.

Copies of all analytical testing, such as waste characterizations, for waste streams and other materials should be retained in the environmental records.

Copies of all operating permits, application forms, and associated reports should be retained for at least five years after the permit has been renewed.

Health & Safety

OSHA requires that employers keep annual records of medical treatment, accidents and illnesses. Employers must use the OSHA 300A and 301 Form to document these incidents. These forms must be posted for the entire month of February each year regardless of whether there were any recordable incidents or not.

OSHA regulations require that copies of Material Safety Data Sheets for all chemicals used in the company must be kept and made available to employees. Outdated Material Safety Data Sheets (MSDSs) must be maintained for 30 years or as long as the company is in business (whichever is longer). This includes materials that are no longer used in the company as well as MSDSs for products that are still used, but the product formulation has changed so the previous MSDS is outdated.

Records of all safety training must be maintained. Records should include, but not limited to, job specific training, general awareness training, fire safety training, etc.