Search

EPA Delays Recent Hazardous Waste, PFAS Final Rules

Posted on 2/5/2025 by Lion Technology Inc.

Delayed RCRA, TRI Regulations Now Take Effect 3/21

US EPA has delayed the effective date for two recently published Final Rules—a rule to revise or “correct” several RCRA requirements for hazardous waste generators and a rule adding 9 PFAS to TRI reporting list under EPCRA—until March 21, 2025.

Delayed: RCRA Corrections—Generator Improvements, Hazardous Waste Pharmaceuticals, and 2018 Definition of Solid Waste Rules

A Final Rule to revise and clarify several RCRA requirements for hazardous waste generators now takes effect on March 21, 2025. The Final Rule affects four specific requirements in 40 CFR Part 262:
 
  • Limits for small quantity generators (SQGs) accumulating acute hazardous waste.
  • Exclusions under RCRA for managing samples used in treatability studies. 
  • "Closure" of units at a large quantity generator (LQG) site.
  • Some hazardous waste pharmaceuticals (HWP) shipped on the manifest. 
EPA included these revisions in a RCRA rule in 2023, but withdrew them after industry stakeholders responded with legitimate questions and concerns. Those comments led EPA to revise and clarify some of the withdrawn provisions before republishing them recently.

rcra hazardous waste drums

Delayed: Statutory Addition of PFAS to the TRI Reporting List

EPA has delayed the effective date until March 21, 2025 for the Final Rule adding 9 PFAS to the TRI reporting list, beginning in Reporting Year 2025. That means the first TRI submissions covering these nine substances will be due July 1, 2026.

Without further action, EPA’s delay of the effective date will not affect the reporting requirement taking effect for 2026 submissions. Facilities that are already tracking any of these nine chemicals for reporting purposes should, it seems, continue to do so unless told otherwise. 

Adding PFAS to the TRI list is something EPA is required by law to do, namely the Emergency Planning and Community Right-to-Know Act (EPCRA) and the 2020 National Defense Authorization Act (NDAA). 

As of February 2025, the TRI reporting regulations list about two hundred PFAS by name (40 CFR 372.65(d)). In 2023, EPA designated PFAS a “chemical of special concern” under EPCRA. Chemicals of special concern are subject to lower reporting thresholds than other listed substances (40 CFR 372.28).
 PFAS regulations
EH&S Cheat Sheet: EPCRA TRI Reporting Due July 1 

Find a Post

Compliance Archives

Lion - Quotes

The instructor kept the class engaged and made learning fun. There was a lot of information to cover but time flew by. I will definitely use Lion in the future!

Chelsea Minguela

Hazmat Shipping Professional

I like the consistency of Lion workshops. The materials are well put together and instructors are top notch!

Kevin Pylka

Permitting, Compliance & Environmental Manager

This course went above my expectations from the moment I walked in the door. The instructor led us through two days packed with useful compliance information.

Rachel Stewart

Environmental Manager

The course was very informative and presented in a way that was easily understood and remembered. I would recommend this course.

Jeffrey Tierno

Hazmat Shipping Professional

The instructor was very dedicated to providing a quality experience. She did her best to make sure students were really comprehending the information.

Stephanie Venn

Inventory Control Specialist

I chose Lion's online webinar because it is simple, effective, and easily accessible.

Jeremy Bost

Environmental Health & Safety Technician

I tried other environmental training providers, but they were all sub-standard compared to Lion. I will not stray from Lion again!

Sara Sills

Environmental Specialist

Lion's online training is more comprehensive, has better slides, and is a superior training experience than what I would get from other trainers.

Robert Brenner

District Environmental Manager

Very good. I have always appreciated the way Lion Tech develops, presents and provides training and materials.

John Troy

Environmental Specialist

Energetic/enthusiastic! Made training enjoyable, understandable and fun!

Amanda Walsh

Hazardous Waste Professional

Download Our Latest Whitepaper

Your hazmat paperwork is the first thing a DOT inspector will ask for during an inspection. From hazmat training records to special permits, make sure your hazmat documents are in order.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.