What to Know about the EPA Final Rule and Hazardous Waste

Ruling History

The Environmental Protection Agency (EPA) proposed the Hazardous Waste Generator Improvements Rule in 2015 as a way to update the original 1980 legislation. Known as the “Final Rule,” it was designed improve the entire hazardous waste generator program and strengthen environmental protection, while offering businesses the flexibility and certainty they needed to continue operations. The Final Rule went into effect in May 2017 and, as of May 2021, has been adopted by 34 states.

Based on concerns from evaluations performed in 2004 and 2013, the Final Rule made over 60 changes to the hazardous wasted generator regulations so it would now:

• Be easier to understand
• Allow better compliance
• Provide more flexibility
• Close regulatory gaps

Ruling Summary

Some of the more than 60 changes include:

1. Renotification. Beginning September 1, 2021, small quantity generators (SQGs), which generate between 100 and 1000 kg of hazardous waste per month, are required to renotify EPA of their hazardous waste activities every four years by submitting a completed Notification of Resource Conservation and Recovery Act (RCRA) Site Identification Form (Form 8700-12). Many states offer the electronic reporting system, MyRCRAID.
2. Episodic Generation. Generators are allowed to maintain their existing category provided they comply with streamlined set of requirements.
3. Consolidation. A very small quantity generator (VSQG) will be allowed to send hazardous waste to a large quantity generator (LQG) under control of the same person.
4. Marking and Labeling. Container labels must indicate the hazards of the contents, within flexibility allowance.
5. Drip Pad and Containment Buildings. SQGs may accumulate hazardous waste on drip pads and in containment buildings within specified provisions.
6. Emergency Preparedness and Planning. Generators must make and save documentation showing they have attempted to make arrangements with local emergency responders.
7. Waiver to 50-foot Requirement. LQGs are allowed to apply for a waiver from this requirement if the fire marshal approves.
8. Use of inventory logs or monitoring equipment or other records which show that the tank has been emptied every 90 or 180 days for batch process and for continuous flow, and that hazardous waste volumes exit within 90 or 180 days, are required.
9. Closure Provisions. Closure as a landfill is required if LQGs accumulating hazardous wastes in containers fail to clean close.

To have your hazardous waste managed in compliance with the EPA ruling, contact a regulated waste removal service.

GreenServ is a premium waste management company serving the mid-south region, including Mississippi, Louisiana, Arkansas, and Tennessee. We facilitate every step of the waste disposal process. Call us at 662-533-0940 or complete the form on this page and we’ll be happy to answer any questions you might have.