On November 28, 2016, the EPA published the final Hazardous Waste Generator Improvements Rule, providing a much-needed update to the Resource Conservation and Recovery Act (RCRA) hazardous waste generator regulations. By enhancing facility safety and the communication of onsite risks to emergency responders, the revisions are a significant attempt to address the challenges hazardous waste programs face. The final rule makes the regulations easier to understand, and provides greater flexibility in how hazardous waste is managed, to better fit today’s business operations.
While the new requirements are fairly straightforward, they do bring important changes to the rules surrounding labeling, storage, waste aggregation, and reporting requirements. These changes will affect how hazardous waste generators manage containers, areas, buildings, tanks, and other related equipment, with more focus on storage areas and containers that include both satellite accumulation and central accumulation container, areas, and buildings. The rule also addresses pre-transport requirements for hazardous waste shipments and changes to reporting requirements.
For most, compliance of the revisions should be straightforward, but it’s critical that companies know exactly what is required of them. Now is a good time for companies to begin developing a strategy for implementing the new rule changes, and identifying outside resources that can assist with meeting the compliance requirements by streamlining the creation of complete and properly-formatted reports.
A few significant changes include:
- Generators are required to label containers with a clear indication of the hazards of the waste material and the date accumulation started. At time of shipping, waste containers must now be clearly labelled with the appropriate RCRA waste codes so that the receiving facility knows how to handle the waste appropriately.
- Two key provisions aimed at increasing the flexibility for generators of hazardous wastes have been added. The first allows hazardous waste generators to avoid the increased burden of a higher generator status when generating episodic waste provided the episodic waste is properly managed. The second permits a very small quantity generator (VSQG) to send its hazardous waste to a large quantity generator under control of the same person.
- Beginning in 2021, the EPA is implementing RCRA Subtitle C re-notification requirements for SQGs (due by September 1, every four years).
- LQGs are now required to prepare and submit a quick reference guide for the existing Waste Contingency Plan. This is to provide emergency response personnel with key information in an easy to disseminate format.
The final rule went into effect at the federal level on May 30, 2017, and states are likely to begin adopting the new requirements over the next year or so.
 Join Julian Moffat for the on-demand webinar Hazardous Waste Labeling and Marking: Managing Updated Compliance Obligations Under the EPA’s Final Rule.
Julian Moffat is the director of environmental solutions at VelocityEHS, a leading cloud EHS software company dedicated to helping its customers reach their EHS and sustainability goals faster through a simple and intuitive platform that is more affordable and faster to implement. To learn more about how VelocityEHS can help you meet your environmental requirements, visit www.EHS.com/solutions/waste-compliance or call 1-866-919-7922 to talk to an expert today. |