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Almost every industrial site we audit has hazardous waste authorisation. Almost none can reconcile their own numbers on the first attempt.
What the rules require
Units generating, storing, handling or disposing of hazardous waste need authorisation from the State Pollution Control Board under the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016. The authorisation specifies which wastes, in what quantities, stored how, and disposed through which route.
The four numbers that must agree
Quantity generated. Quantity stored.
Quantity dispatched. Quantity reported in
the annual return.
These are usually tracked by four different people, in four different places,
on four different bases. They only have to disagree once for the whole record
to come into question.
The fix is unglamorous: reconcile monthly, not annually. A discrepancy found in month two is a clerical correction. The same discrepancy found in April is a finding.
Storage - what inspectors look at
- Impervious flooring with containment - so a spill stays inside the area
- Covered storage, protected from rain
- Labelling per the prescribed format, legible and current
- Segregation of incompatible wastes
- Storage period within the permitted limit - waste that has sat beyond it is a visible, dated problem
- Access control and spill response equipment
The manifest system
Every consignment moving off site must be accompanied by the prescribed movement document, with copies flowing between generator, transporter and receiving facility. Missing manifest copies are among the most common findings, usually because the returned copy was never chased after the truck left.
Your liability does not end at the gate
Handing waste to a transporter does not transfer responsibility. If the receiving facility is not authorised for that waste category, or the waste never arrives where it was supposed to, the problem comes back to the generator.
Verify authorisation status before waste moves - for the transporter and for the TSDF or recycler - and keep evidence that you did.
Where the data goes next
Hazardous waste figures feed your Form-V Environmental Statement, your annual hazardous waste return, and are examined in every environmental audit and board inspection. One reconciled set of numbers serves all of them.
Frequently Asked Questions
Who needs hazardous waste authorisation?
Units that generate, store, handle, transport or dispose of hazardous waste generally require authorisation from the State Pollution Control Board under the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016. Applicability depends on the waste streams and quantities involved.
How long can hazardous waste be stored on site?
The rules prescribe a maximum storage period, which can vary by circumstance and may be extended with permission. Waste held beyond the permitted period is straightforward for an inspector to identify, since storage records are dated.
What is the manifest system?
It is the set of movement documents that must accompany every hazardous waste consignment leaving the site, with copies flowing between the generator, transporter and receiving facility. Missing returned copies are one of the most common compliance findings.
Is our liability over once the waste leaves the site?
No. If the receiving facility is not authorised for that waste category, or the consignment does not reach an authorised destination, the responsibility returns to the generator. Authorisation status of transporters and receiving facilities should be verified before waste moves, with evidence retained.
What causes most hazardous waste audit findings?
Reconciliation. Quantities generated, stored, dispatched and reported are typically tracked separately and rarely agree on first examination. Monthly reconciliation instead of annual is the single most effective preventive measure.
Need expert help with this?
We handle hazardous waste authorisation, storage compliance, manifest systems, recycler verification and annual returns.
Get Help With Hazardous Waste