The following post is provided by our guest author, Karen Lutz from TRC Environmental Corporation. Karen can be reached at email@example.com.
The U.S. Environmental Protection Agency published proposed revisions to Hazardous Waste Generator regulations in September 2015. The public comment for the proposed revisions closed at the end of December 2015 and the revisions are currently planned to be published as final in October 2016. Revisions to definitions, hazardous waste identification requirements, and hazardous waste generator standards could impact any facility that generates hazardous waste.
The intent of the proposed rule revisions are to address gaps in the regulations, provide greater flexibility managing hazardous waste in a cost-effective manner, and making general language updates (e.g. technical corrections, removal of obsolete references, improved readability, and clarification of ambiguities). While some items like hazardous waste determinations, labeling, closure requirements, and contingency planning have become more stringent, items like waste consolidation at CESQGs, episodic waste generation, and the waiver from the 50-foot rule have become less stringent.
What are the main revisions to the rules?
The updated regulations have several items that will affect hazardous waste generating facilities. Highlights include:
Rule Adoption and Implementation
How to Prepare for the Final Revisions