Regulatory Updates: Hazardous Waste Generator Improvements Rule

In November 2016, the above mentioned rule was finalized, which marked a historic update to the Federal RCRA regulations as it pertains to hazardous waste generators.  The major changes in the rule went effective May 30, 2017.  Authorized states will have to adopt the more stringent regulations typically by July 1, 2018 (July 1, 2019 if state law change is required).  If you aren’t already, you need to ask yourself immediately, when and how are we affected?  The following are the noteworthy changes and states affected in the region:
All regions
  • An overall re-org and re-structuring of 40 CFR 262 to streamline navigation and understanding. For example previously known conditionally exempt small quantity generators (CESQGs) are now known as very small quantity generators (VSQGs).
  • Updated retention policies for waste determination records.
  • More stringent regulations
    • An expansion of the marking and labeling requirements for hazardous waste containers in satellite and central accumulation areas and for tanks.
    • Small quantity generators (SQGs) must “re-notify” federal and/or state environmental agencies every four years, starting in 2021.
    • Consolidating and updating the “closure requirements” for hazardous waste accumulation units.
    • Updating RCRA biennial reporting in 40 CFR 262.41.  Includes the requirement of facilities that recycle hazardous waste without storing it to submit a Biennial Report.
    • Requiring large quantity generators (LQGs) to include a quick reference guide with their contingency plan.
  • Less stringent regulations
    • VSQGs can send their hazardous waste to an LQG control of the same person as specified in 40 CFR 262.10.
    • Relaxed standards for VSQGs and SQGs that allow for them to keep their status despite occasional generator events that may otherwise result in a change of generator status.
    • Waiver allowing LQGs to accumulate ignitable and reactive wastes within a 50 ft. facility boundary with approval from local fire agencies.
Alaska, Iowa, and Territories
  • Because Alaska, Iowa and territories do not manage their own hazardous waste program, Federal RCRA is adopted by default.  As a result, generators must be in compliance with all parts of the final rule by May 30, 2017.
New Jersey and Pennsylvania
  • Because these states are very unique in that they structure their programs directly adopting all Federal hazardous rules by reference, their generators must be in compliance with all parts of the final rule by May 30, 2017.
See the final rule text here. For more information or clarification on how your facility will be affected and the timeline or if you just would like to talk about navigating these updates call your local dedicated Enviroexpert.

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