Waste Management Program
Hazardous waste characterization, generator status determination, storage time limits, manifest procedures, and disposal requirements.
What this document is
This document is a written Waste Management Program that meets hazardous waste generator requirements. It walks contractors through the steps needed to classify waste, set storage limits, prepare manifests, and arrange proper disposal.
The regulation that requires it
Federal rules appear in 40 CFR 262, which covers standards applicable to generators of hazardous waste. Subpart A requires determining generator category, Subpart B covers the hazardous waste determination, and Subpart C addresses the manifest system. In California the parallel requirements are found in Cal EPA Title 22, Division 4.5, Chapters 12 and 13. These rules mandate that generators characterize waste, never exceed allowed storage times, use proper manifests, and ship only to permitted facilities.
Who needs it
Construction contractors, demolition firms, and specialty trades that generate paint waste, solvents, adhesives, or contaminated soil need this program. Any employer classified as a hazardous waste generator under federal or state rules must maintain one. California contractors face both federal RCRA rules through 40 CFR 262 and the stricter Cal EPA Title 22 standards enforced by the Department of Toxic Substances Control.
What happens without it
Inspectors can issue Serious citations when a written program is missing or incomplete. Willful violations carry significantly higher penalties under the current OSHA penalty schedule. California DTSC and Cal/OSHA routinely inspect job sites that handle chemicals or demolition debris, increasing the chance of discovery. Multi-employer sites can result in citations to both the creating contractor and the controlling employer.
What's included in the generated document
- Waste characterization procedures
- Generator category determination table
- On-site accumulation time limits and labeling requirements
- Manifest preparation and tracking instructions
- Disposal and recordkeeping responsibilities
How to implement it at your company
- Download the PDF and replace the placeholder company name and site information with your own details.
- Have your safety manager or qualified person review the waste streams generated on your projects and complete the characterization section.
- Train field supervisors and employees who handle waste on the procedures in the document.
- Post the program at each job site where hazardous waste is stored and keep a copy in your safety manual.
- Update the document annually or whenever you introduce new materials that change your waste profile.