Enforcement in New England
This statement has been developed to provide Pfizer Inc with Regional EPA guidance to facilitate future compliance at the Groton, Connecticut facility.
RCSA § 22a-449(c)-102(b)(2) requires that hazardous waste generators comply with the requirements of 40 C.F.R. § 265.15 for all hazardous waste storage areas. Forty C.F.R. § 265.15 requires that a facility conduct inspections and record those inspections in an inspection log or summary. Forty C.F.R. § 265.15(d) provides that "[a]t a minimum, these records must include the date and time of inspection, the name of the inspector, a notation of the observations made, and the date and nature of any repairs or other remedial actions." Observations made during inspections required by 40 C.F.R. §§ 265.15, 265.174, 265.195 and 265.1052 must be recorded in an inspection log or summary. A company may choose its own format for recording such observations as long as the format provides for full documentation of observations and any remedial actions taken. If a checklist is chosen as the documentation format, the checklists must be filled out completely. Each item on the checklist must be addressed by means of a checkmark or other item-specific notation.