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REGULATION GUIDANCE: Any person who generates a waste shall determine if the waste is a hazardous waste as specified in Title 22 California Code of Regulations (CCR). There are wastes that are listed as hazardous wastes. There are wastes that exhibit one or more of the hazardous waste characteristics: toxic, corrosive, reactive or ignitable. CORRECTIVE ACTION: Immediately make a hazardous waste determination for each waste , and manage it according to Title 22 CCR. Use Safety Data Sheets (SDS), waste sampling and test results or other knowledge to support your hazardous waste determination. Waste testing must be done using methods specified in Title 22 CCR including sections 66261.20-24. Submit a statement and supporting documentation with your hazardous waste determination. Demonstrate current storage and labeling for wastes determined to be hazardous wastes. Provide disposal records for wastes determined to be hazardous wastes and stored longer than the number of days specified in Title 22 CCR for your hazardous waste generator status. So Bob, I will need two statements, one for the open drum of oily waste and aerosol and another statement for the lead acid battery. First statement should include how you will be managing the open drum. If it is determined to be hazardous waste and will be disposed of, I will need a disposal record showing quantity, how it was transported and by who and where it will be taken to (just like the information on a consolidated manifest). Or, if it is within the 180 days and an accumulation date is known, label with hazardous waste label and add the 6 items of required information and a lid for the drum. If it is deemed non-hazardous, you will need to provide documentation such as analytical lab testing results showing material is non-hazardous. Second statement should include whether the lead acid battery observed at the yard is waste or product. If waste, please tell how it will be managed and provide disposal record. For item 605 for the labeling, the photo was taken from a distance where the labels are not clear. To correct this, please provide statement stating that the drums were labeled and explain what information was added, as stated on the full report: REGULATION GUIDANCE: All hazardous waste containers shall be marked with the following information: the words "Hazardous Waste" name and address of generator, hazardous properties, physical state, composition (contents), accumulation start date. For item 608 for the oil filters, on the full report is written: OBSERVATION: This facility generates drained used metal oil filters. A complete three year bill of lading record for used oil filter recycling was not observed during the inspection. The following bills of lading contained incomplete information: 2