Hazardous Waste Generator Improvements

The final Hazardous Waste Generator Improvements Rule went into effect on the federal level on May 30, 2017, amending parts of the regulations promulgate pursuant to the Resource Conversation and Recovery Act (RCRA). The RCRA was passed in 1976, and provides the national regulatory framework for solid and hazardous waste management.

This final rule includes over 60 changes to the hazardous waste generator regulations that clarify existing requirements, increase flexibility, and improve environmental protection. These changes also adjusted the regulations to make them easier to follow and make certain technical corrections.

Key Provisions
  • Hazardous waste generator retains its status following such certain episodic events (i.e. spill) provided the waste is properly managed
  • Very Small Quantity Generators (VSQGs) will be allowed to send hazardous waste to a Large Quantity Generator (LQG) for consolidation provided the LQG and VSQG are under the control of the same person
Other Items
  • Improves hazardous waste risk communications
  • Clarification on how to quantify wastes
  • Changes to the requirements for Satellite Accumulation Areas
  • Definition for Central Accumulation area
  • Clarification on how wastes are identified and what records must be kept
  • Updates to requirements for recycling hazardous waste without storing it
  • Requirements for SQGs to re-notify every four years starting in 2021 (Re-notification must be done by September 1st of the reporting year)
  • Clarification on generator status for those that generate acute and non-acute wastes
  • Conditionally Exempt Small Quantity Generator now Very Small Quantity Generator
  • Updates on what information needs to be provided to the Local Emergency Planning Committee
  • Distinction between conditional requirements and independent requirements for exempted wastes, as well as an expanded list of exempted wastes

The changes will become effective in states that have authorized hazardous waste programs as the states update their regulations. With any new or revised regulation it is expected that there will be a learning curve, especially as the implementation moves to the states. The EPA has provided several resources on the Final Rule to give a better understanding about the changes that will go into effect.

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