March 16, 2020

Key Takeaways from the EPA Hazardous Waste Generator Improvement Rule

The Environmental Protection Agency’s (EPA) Hazardous Waste Generator Improvement Rule went into effect May 30, 2017 and includes some important tasks that hazardous waste generators—whether they produce small or large waste quantities—must complete. 

Sample of the New EPA Hazardous Waste Requirements

  • Hazardous waste generators have always had to determine how much waste they generate and whether it is considered hazardous. The EPA has placed more emphasis on generators to make an “accurate” waste determination, to document these waste determinations, and to keep those records for three years. When labeling containers, a generator  must continue to label the container with the words “hazardous waste”. There also needs to be a description of the content’s hazards and characteristics, which can include Department of Transportation labels, applicable Occupational Safety and Health Administration (OSHA) pictograms, or wording that describes the hazards.  This applies to containers in both the satellite accumulation areas (SAA) and central accumulation areas (CAA).

  • Organizations can exceed their designated waste amount once per year—although they can petition for an additional event if it is unplanned. To comply with this rule, the waste generator must have an EPA ID and notify the agency 30 days prior to the episode. In the case of an unplanned emergency, the facility must notify the EPA within 72 hours.

  • Before transporting waste or offering it for transport, a waste generator must mark each container with applicable waste codes.

  • Both small and large waste generators have to re-notify the EPA of their waste activities in 2021 and every four years after.

These are just a few highlights from the regulations found in the EPA’s new rule. To obtain further detail or to get help with meeting requirements under the rule, please contact a Compliance Specialist at 855-602-6279.


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