Hazardous Waste Determination Failure Register

PROBLEM: In EPA Docket RCRA-09-2026-0061, Agilent Technologies (Santa Clara, CA, EPA ID CAR000058545) was inspected December 11, 2025 and found to have failed to perform a waste determination, failed to keep satellite accumulation under 55 gallons, and failed to close hazardous waste containers. EPA and the company settled for $11,250. A waste determination is the first step in the whole RCRA chain — if it is skipped, everything downstream (accumulation, labelling, disposal) is built on an unknown waste.

SOLUTION: An IBM Cloud Ideas compliance improvement that maintains a waste-determination register: every waste stream gets a determination record (characteristics, codes, date, determiner) before it can be accumulated, and any container without a linked determination, any satellite area over 55 gallons, or any open container is flagged the same day.

EVIDENCE BASIS: DOCUMENTED — EPA Expedited Settlement Agreement, Docket RCRA-09-2026-0061: Agilent Technologies, Santa Clara, CA; inspected Dec 11, 2025; waste-determination failure (22 CCR 66262.11 / 40 CFR 262.11), satellite-accumulation failure (22 CCR 66262.15(a)), failure to close containers; $11,250 civil penalty.