How long should I keep waste records?

It is important to keep clear and complete records for all asbestos waste, and the method of keeping these records currently accepted by the EPA’s National Emissions Standards for Hazardous Air Pollutants (NESHAP) regulations is through a Waste Shipment Record (WSR). Before we go into how long WSR’s should be kept, it is important to understand what a WSR is and how it works.

WSR’s are composed of three parts and require the signatures of three separate parties: the waste generator, the transporter, and the waste disposal site operator. A “waste generator” is defined as the owner or operator of any concern that generates asbestos waste. This includes asbestos mills, manufacturers, fabricators, demolition or renovation projects, etc. The waste generator is responsible for filling out the first part of the WSR, and then transfers the waste shipment and WSR to the transporter. It is important that the waste generator keep a copy of the WSR signed by the transporter for their records.

When the transporter delivers the waste shipment to the waste disposal site, they should give a copy of the WSR to the waste disposal site operator. If there is a second transporter, both transporters must sign the WSR. It is recommended, although not required, that the transporter keep a copy of the WSR signed by the waste disposal site operator for their records. After the waste shipment has been delivered, the waste generator should receive a copy of the WSR signed by the waste disposal site operator. If the waste generator has not received such documentation within 35 days, they should take steps to locate the shipment. If they still have not received it after 45 days, they must submit an exception report.

It is possible for a WSR to be documented incorrectly, so if the waste disposal site operator notices any discrepancies between the WSR and the waste shipment itself, it should be noted on the WSR before it is sent back to the waste generator. The waste generator should also be contacted to find out the reason for the discrepancy. Discrepancies that cannot be resolved require the waste disposal site operator to submit a discrepancy report to the proper government authority. Both waste generators and waste disposal site operators must keep WSR’s on file for two years after the removal of the asbestos waste.