Hazardous Waste Generator Improvement Rules

Believe it or not, Michigan is in the process of adopting the federal Hazardous waste Generator Improvement Rule (GIR) sometime this Spring.  Now I know what you’re thinking, Trump was supposed to get rid of all those pesky hazardous waste rules.  Well, he is still working on that, but in the meantime the Michigan legislature is doing something that makes sense for the hazardous waste management community.  The GIR became effective (as far as the feds go) back in May 30, 2017.  EGLE is off the hook for adopting the rule until the Michigan legislature adopts the rule which is currently in the works.  No, we still don’t have an effective date for Michigan’s version of the rules, but it is hoped that EGLE will know in the next few months. 
 
This final rule includes over 60 changes to the GIR regulations that clarify existing requirements, increase flexibility, and improve environmental protection.  Some changes reorganize the regulations or make minor technical corrections.  Here are some of the highlights:
 
Episodic Waste Events:  Allowing a very small quantity generator (VSQG, formerly CESQG) or a small quantity generator (SQG) to maintain its existing generator category in the case of an event in which the VSQG or SQG generates a quantity of hazardous waste in a calendar month that would otherwise bump them into a more stringent generator regulatory category.  We have worked with clients as they wrestled with the old rule after they performed a cleanup, plant maintenance, found obsolescent chemicals on their premises, or they made changes to operations that left them with a large amount of chemicals they no longer needed and it threw them over the limits.  Allowing episodic waste events will be a welcome change. 
 
Waste Co-Mingling:  This rule provides some cost savings to companies by allowing a VSQG to send its hazardous waste to a sister company (with the same owner/operator) so that it can be consolidated with the larger facility’s waste streams and then be sent to a TSDF. 
 
Emergency Response Plan Notifications:  The rule includes Local Emergency Planning Committees among those organizations with which a generator may make response arrangements.
 
Quick Reference Guides:  The GIR requires that new and existing LQGs submit quick reference guides to local emergency responders.  The quick reference guides are intended to provide easy access to key information during an event. 
 
SQG Re-Notification:  SQGs will be required re-notify EGLE every four years regarding their generator status.  Currently, SQGs only notify once under the current system. 
 
Labeling and Marking Containers:  GIR revises the regulations for the labeling and marking of containers and tanks so that these labels and markings clearly indicate the hazards of the waste contained inside the container. 
 
Keep up on the latest regarding GIR by checking out the EGLE GIR web page.  We’ll also keep an eye on it and report back in future newsletters.  

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