The New Hazardous Waste Generator Improvements Rule
With Hazardous Waste Generator Improvements Rule, EPA has made changes to RCRA hazardous waste regulations. Learn what's different and when to comply.
Called the “Hazardous Waste Improvements Rule,” EPA has issued updates and changes to its Resource Conservation and Recovery Act (RCRA) hazardous waste regulations.
⚡ TL;DR: The EPA’s Hazardous Waste Generator Improvements Rule introduced over 60 changes to RCRA regulations, including new consolidation options for very small quantity generators (VSQGs). Understand how these rules affect your waste classification, accumulation, and reporting requirements.
⚠️ What’s at stake: Misinterpreting these regulatory changes can result in non-compliance citations, improper waste handling practices, and EPA enforcement action. Facilities with multiple locations must correctly apply consolidation rules to avoid violations.
When: EPA has made over 60 changes which are geared to make technical corrections, clarify, increase flexibility and improve environmental protection. The changes will not go into effect until May 30, 2017, then every state but Iowa and Alaska will have until mid-2018 to implement and adopt (or not adopt) the less stringent requirements.
Consolidation of VSQG Waste at LQGs
EPA now allows very small quantity generators (VSQG, now the term for the former “conditionally exempt small quantity generator”) to consolidate waste at a large quantity generator (LQG) under the control of the same person. In some cases, organizations have satellite locations that qualify as a VSQG and could take advantage by consolidating together. VSQGs would need to mark and label their waste as “Hazardous Waste,” and indicate the hazards associated with the contents. LQGs would notify on the Site ID Form 30 days prior to receiving the waste that they are participating in this activity, who the VSQG is, maintain records for each shipment for 3 years, mark the accumulation units with the date the HW was received, manage consolidated waste as LQG waste and report in annual and biennial reports.
HW Determinations- Generator’s waste must be classified at its point of generation and at any time during the course of its management. Container markings and labels apply at the point of generation as well.
Does your facility have multiple locations handling hazardous waste under different generator categories? iSi’s hazardous waste specialists help multi-location facilities optimize waste consolidation and compliance under the Improvements Rule. Get regulatory guidance →
Frequently Asked Questions
Q: What is the Hazardous Waste Generator Improvements Rule and when did it take effect?
The EPA’s Hazardous Waste Generator Improvements Rule made over 60 changes to RCRA regulations to provide technical clarifications, increase operational flexibility, and improve environmental protection. The rule took effect May 30, 2017, with state implementation required by mid-2018, though most states have adopted these changes.
Q: Can a very small quantity generator (VSQG) consolidate waste with a large quantity generator (LQG)?
Yes, under the Improvements Rule, VSQGs can consolidate hazardous waste at an LQG under common control if waste is properly marked and labeled. The LQG must notify the EPA 30 days before receiving consolidated waste, maintain shipment records for three years, and manage consolidated waste per LQG requirements in annual and biennial reporting.
Q: When must hazardous waste be classified under RCRA?
Hazardous waste must be classified at its point of generation by the facility that produces it, and reclassification can occur at any time during waste management. Container markings and hazard labels must be applied at the point of generation and maintained throughout the waste management process.
Q: How does the Improvements Rule affect small businesses with multiple locations?
Organizations with satellite facilities that qualify as VSQGs can benefit by consolidating waste streams at a designated LQG location, reducing administrative overhead and improving efficiency. iSi Environmental helps multi-location facilities in Kansas City, Wichita, and Tulsa optimize their hazardous waste management under these consolidated rules.
💰 The cost of non-compliance: EPA penalties for hazardous waste misclassification and improper consolidation can reach $25,000 to $50,000+ per day per violation. Facilities with multiple locations that fail to correctly apply Improvements Rule requirements face escalated enforcement and remediation costs.
Every satisfactory compliance program starts with knowing where the gaps are. iSi Environmental helps industrial and manufacturing facilities understand and apply RCRA hazardous waste regulations correctly. Schedule a compliance review →
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