Category: Hazardous Waste Management

Oil barrels or chemical drums stacked up

Counting Hazardous Waste? Don’t Include These

As a hazardous waste generator you are required to determine your generator status or category by counting how much hazardous waste you have on-site. Yesterday we discussed steps for counting your hazardous waste and included wastes that are exempt from counting for your generator status, primarily because they are managed under other regulations, such as […]

hazmat inspection/counting hazardous material generation

Four Steps for Counting Hazardous Waste

Hazardous waste generators are required to count their hazardous waste in order to determine their generator status. The U.S. Environmental Protection Agency’s (EPA) new Hazardous Waste Generator Improvements Rule, which is effective May 30, 2017, on the federal level, includes a consolidated provision on determining your generator status. Here are some tips for counting your […]

hazardous materials

Are Satellite Accumulation Area Rules Still the Same?

Yes … The Hazardous Waste Generator Improvements Rule (Final Rule), which goes into effect at the federal level on May 30, 2017, adds many new provisions. However, the thrust of the Final Rule is to clarify existing provisions, including the requirements for satellite accumulation areas (SAAs). Many generators of hazardous waste use SAAs at their […]


EPA’s Revised Pesticide Rule Follows State Lead

One motivation behind EPA’s comprehensive revisions of its certification requirements for applicators of restricted use pesticides (RUP) is the need for the federal regulations to catch up with authorized state programs. Issued under authority of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) in 1974, the original RUP applicator certification requirements (40 CFR part 171) […]


Sending VSQG Hazardous Waste to an LQG – A Win/Win

The final Hazardous Waste Generator Improvements Rule (Rule), published in the Federal Register on November 28, 2016, contains two of what the U.S. Environmental Protection Agency (EPA) refers to as “voluntary programs”—meaning that generators of hazardous waste have the choice of whether to comply with the new programs’ requirements. The first program is a set […]


New Generator Rule = New Labeling and Marking Requirements

The Hazardous Waste Generator Improvements Rule (Rule), finalized on October 28, 2016, will require hazardous waste large quantity generators (LQGs) and small quantity generators (SQGs) to make many changes as to how they manage their hazardous waste. Because the current generator requirements will be in place in most states for months and months to come—that […]


Hazardous Waste Generator Rule Changes Finalized

As frequent visitors to EPA’s Resource Conservation and Recovery Act (RCRA) Online database already know, the Agency’s hazardous waste regulations prompt a constant stream of questions from both regulated entities and RCRA-authorized states about applicability, lack of clarity, and regulatory gaps. A small fraction of EPA’s answers and interpretations responding to such questions have now […]