RCRA Hazardous Waste Generator Improvements Rule

The final RCRA hazardous waste generator improvements rule will soon be published by EPA. According to the pre-publication version of the rule, it will include more than 60 revisions and new requirements with the goal of improving compliance understanding through increased user-friendliness, improved flexibility, gap closure, clarifications, and technical corrections. A major focus of the revision is to foster improved compliance with regulations and to support efficient implementation by the states. With the rulemaking, EPA has reorganized and consolidated most of the generator regulatory program into 40 CFR 262, with the exception of the RCRA air emissions standards and the land disposal restriction requirements. 

Changes to RCRA include, but are not limited to the following:

  • New requirements for documentation, labeling, and marking of hazardous waste containers. Label identification of the specific hazards associated with hazardous waste will be required.
  • Small Quantity Generators (SQG) now must re-notify EPA or authorized state of their generator status and wastes generated every four years. (This is only required once under the current rule).
  • Conditionally Exempt Small Quantity Generators (CESGQ) are now called Very Small Quantity Generators (VSQG).
  • VSQG can send hazardous waste to a LQG under control of the same person for consolidation purposes.
  • VSQGs and SQGs can voluntarily maintain existing regulatory status if their hazardous waste generation spikes due to an episodic event that would otherwise move them into a higher generator category.
  • Large quantity generators (LQG) must notify EPA or their authorized state when they plan to close their facilities.
  • LQG must also prepare a quick reference guide for contingency plans to assist responders in an emergency.
  • Facilities that recycle hazardous waste without storing the waste must now prepare and submit a biennial report.
  • Clarification of the waste determination process, mixture rule, and use of generator knowledge for waste determinations.
  • Clarification on selection of generator category when both acute and non-acute hazardous wastes are generated.

The new rule will be effective six (6) months from the day it is published in the Federal Register. It is yet to be determined how Indiana and other delegated states will adopt all or parts of the rule and the timing for rule adoption.

For a complete copy of the finalized rule, click here.

Please contact Mack Overton or John Wellspring with any questions about how the new RCRA changes could affect your facility.

Blog Author


Mack Overton
Vice President, EHS Compliance Services

Contact Mack at moverton@keramida.com.