HWGI rule - Summary of important points

The Environmental Protection Agency’s (EPA) Hazardous Waste Generator Improvement (HWGI) rule has been in effect since May 30, 2017.  Regardless of generator status designation, there are some important tasks generators must complete.  Here is a summary of the most important of those requirements.

·        Episodic events – Generators can exceed their designated generator status threshold once per year.  Additionally, they can petition for an additional “unplanned” event within the same year.  Generators must have an EPA ID and advise the EPA at least 30 days prior to the event.  In the case of an “unplanned” emergency, the generator must advise the EPA with 72 hours. (§262 subpart L)

·        Re-notification – SQGs are required to re-notify of waste activities using Form 8700-12 every four years starting in 2021.  LQGs continue current system of re-notification as part of its biennial reporting requirement. (§262.18(d))

·        Pre-transport marking & labeling – Generators must mark their hazardous waste containers with applicable waste codes prior to shipping offsite for disposal. (§262.32(b))

·        Hazardous waste determination and recordkeeping – Generators must accurately determine the hazardous characteristics of waste at their site with emphasis on accuracy.  They are also required to document the determination and retain the determination records for 3 years. (§262.11).