The Hazardous Waste Generator Improvements Rule was published on November 28, 2016 and goes into effect on May 30, 2017. EPA has been evaluating and working on changes to this Rule for some time. And, if you have ever read the regulation, you know it was difficult read, and therefore can be difficult to understand. Summary sheets and supporting documents are available on the EPA website to help understand the extent and intent of the regulation. EPA’s intent was “to make the rules easier to understand, facilitate better compliance, provide greater flexibility in how hazardous waste is managed, and close important gaps in the regulations.”
EPA arranged the improvements into 5 general categories:
Improvements of environmental protection – EPA updated emergency response and contingency planning provisions, and now requires periodic notification of small quantity generator status, and revised labeling and marking requirements.
Provisions to improve compliance – EPA clarified guidance, revised biennial report forms and changed the name of the lowest generator status from Conditionally Exempt Small Quantity Generator to Very Small Quantity Generator (VSQG).
Provisions to increase flexibility for generators of hazardous wastes – EPA is now allowing a VSQG to consolidate hazardous waste with a large quantity generator (LQG) that is under the control of the same person before sending it on to management at a RCRA-designated facility, provided certain conditions are met.
Reorganization of the regulations – EPA moved the location of a number of generator regulations around so that they are also located in 40 CFR part 262 so that cross-references are no longer needed.