The USEPA Administrator signed a new rule on October 28, 2016 that affects generators of hazardous waste. While this federal rule change became effective last year, authorized states have until July 1, 2019 to adopt the change. The rule finalizes an update to the hazardous waste generator regulations to make the rules easier to understand, provide flexibility in hazardous waste handling for Conditionally Exempt Small Quantity Generators (CESQG), now known as Very Small Quantity Generators (VSQGs), and Small Quantity Generators (SQG), and to close gaps in the regulations. The new Uniform Hazardous Waste Manifest also underwent recent changes.
Many of the rule changes are more stringent and affect generator categories, hazardous waste labeling, hazardous waste determinations, recordkeeping, and mixing rules. Some examples of the more stringent rules include the requirement for Large Quantity Generators (LQGs) to add a Quick Reference Guide to their contingency plans and manage all accumulation areas that cannot be clean closed as a landfill.
New flexibility was added for those experiencing an episodic event (such as a tank clean out or spill). SQGs and VSQGs are now allowed two episodic events per year (one scheduled and one unscheduled) where they generate more waste than the limit for their respective generator status but remain in the same generator category with the same conditions for exemption. Other flexibility in the new rule allows VSQGs to consolidate their hazardous waste with an LQG facility under the control of the same person* and eliminates the need for manifests for transport to the new location.
EnviroScience can help you navigate the new rule and determine what changes will be required at your facility to maintain compliance. To see the status of the rule in your state visit https://www.epa.gov/hwgenerators/where-hazardous-waste-generator-improvements-rule-effect
Contact Chrisie at cbrown @ enviroscienceinc.com if you have questions.
*Individual, trust, firm, joint stock company, Federal Agency, corporation, partnership, association, State, municipality, commission, political subdivision of State, interstate body