Generators of hazardous waste that meet the current Resource Conservation and Recovery Act (RCRA) standards for being conditionally exempt small quantity generators (CESQGs) will be “rebranded” as “very small quantity generators” (VSQGs) when the proposed Hazardous Waste Generator Improvements Rule (Rule) is finalized (most likely this month).
Whether such generators are called CESQGs or VSQGs, their regulatory responsibilities will change only slightly when the Rule goes into effect in their state, although there are a few changes worth noting that will provide more clarity and flexibility. In addition to getting up to speed with new or revised Rule requirements, CESQGs/VSQGs should also keep in mind a few current regulations that continue to apply to them but may not have been on their radar screen.
