Called the “Hazardous Waste Improvements Rule,” EPA has issued updates and changes to its Resource Conservation and Recovery Act (RCRA) hazardous waste regulations.

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.
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