Lion’s office is closed for Thanksgiving until Monday, 11/28. Support for online training is available every day from 8:30 AM to 5 PM ET.
Email for assistance.

Lion News November 2022

RCRA Update: Latest on Generator Improvements Adoption

Posted on November 07, 2022 by Roger Marks

Where is the RCRA Generator Improvements Rule in Effect?

As of November 7, 2022, thirty-nine (39) states have adopted the RCRA Generator Improvements Rule. On the map below, the states in blue have adopted (at least) the mandatory changes from EPA’s 2016 Final Rule.

What is the Generator Improvements Rule?

*Map current as of 11/07/2022

The following states have now incorporated part or all of the RCRA Generator Improvements into their state hazardous waste regulations.

Alabama, Alaska, Arizona, Arkansas, Colorado, Delaware, Florida, Georgia, Hawaii, Idaho, Illinois, Indiana, Iowa, Kentucky, Louisiana, Maryland, Michigan, Mississippi, Montana, Nevada, New Jersey, New Mexico, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, South Carolina, South Dakota, Tennessee, Texas, Utah, Vermont, Virginia, Washington, West Virginia, Wisconsin, and Wyoming.

Add Puerto Rico, American Samoa, the Northern Mariana Islands, and Federal Tribal territories, all of which use the Federal RCRA regulations, to that list.

Update 11/07/2022

The number of states to adopt overhauled hazardous waste management regulations from US EPA’s Generator Improvements Rule has held steady at 39 since our May 2022 update.

Hazardous waste generators in eleven states (and Washington D.C. and Guam) are still waiting for the overhauled, re-organized RCRA requirements to be adopted:  

  • California
  • Connecticut
  • Kansas
  • Maine
  • Massachusetts
  • Minnesota
  • Missouri
  • Nebraska
  • New Hampshire
  • New York
  • Rhode Island

Jump to the latest state-by-state updates.  

Latest State Authorizations from US EPA

Since May, US EPA has authorized several state authorities to enforce new and revised hazardous waste regulations, including changes from the Generator Improvements Rule.

EPA authorized six states for program revisions related to the Generator Improvements Rule before May 2022: Florida, Georgia, Kentucky, Nevada, North Carolina, and South Carolina.

Hazardous waste generators in states that have adopted the Generator Improvements provisions must comply with the new requirements even if US EPA has not yet authorized those state program changes.  

What Does “Authorized” Mean?

US EPA authorizes most states to oversee a state-level hazardous waste program, provided that the state maintains requirements that are at least as stringent as the Federal RCRA regulations.

When a state updates its program, they must submit the changes to US EPA for approval. When EPA gives its final authorization, they officially hand off enforcement powers for those provisions to the state. EPA provides more info about State Authorization on this web page.

New RCRA Rules Under Construction...

All of these states plan to adopt overhauled RCRA standards from US EPA's Generator Improvements Rule in 2023 or 2024.

California (Cal/EPA) is working to adopt the more-stringent (i.e., mandatory) provisions of the Generator Improvements Rule via a “Section 100” rulemaking. Under California state regulations, a Section 100 rule is a change that has "no regulatory effect" (1 CCR §100). 

Connecticut is actively working with US EPA and expects to adopt the Generator Improvements within one year.

Kansas is working to adopt updates to the Federal hazardous waste regulations, including the Generator Improvements Rule, the Hazardous Waste Pharmaceuticals Rule, and other rulemakings. Kansas anticipates that an adoption packet will be available by May 2023.

Maine expects to start drafting changes to its state hazardous waste management rules—including adoption of the Generator Improvements Rule and the Hazardous Waste Pharmaceuticals Rule in 2023.

Massachusetts expects to propose a timeline for adopting the Generator Improvements in early 2023.

Minnesota now plans to publish Land-Related Housekeeping Amendments with a formal public comment period in February 2023. Minnesota will adopt some of the voluntary (i.e., more flexible) provisions from the GIR. Currently, the state does not plan to adopt the allowance for consolidation of VSQG waste nor the relief for episodic generation.

Nebraska is in the process of adopting the Generator Improvements Rule in its entirety, with no precise timeline for implementation.

New Hampshire plans to adopt the Generator Improvements Rule on or before March 30, 2024.

New York will incorporate the GIR into its state regulations as part of an ongoing rulemaking project titled FedReg6, which also includes the Hazardous Waste Pharmaceuticals Rule, revisions to the Definition of Solid Waste (DSW), and relaxed management standards for waste airbags.

Missouri and Rhode Island are working through state-specific issues with EPA before adopting the updated RCRA rules. Both states plan to adopt at least the mandatory provisions.

Washington, D.C. is responding to public comments submitted on a proposal to incorporate-by-reference the revised hazardous waste regulations. The public comment period closed in March 2022.

To complete the above list, Lion is actively seeking an update on the status of the rule change in Guam

Update 05/15/2022
has incorporated-by-reference revised RCRA regulations, including the Generator Improvements Rule provisions, effective May 14, 2022.

Update 02/03/2022
In Vermont, the Generator Improvements Rule provisions are among changes to the hazardous waste regulations that took effect on February 1, 2022. 

In Texas, final action to adopt EPA's Generator Improvements Rule and make other significant changes to the state hazardous and industrial waste regulations took effect on February 3, 2022.

Update 12/23/2021 
Oregon DEQ approved major changes to the state's hazardous waste regulations. Updated rules for hazardous waste generators include the adoption of landmark updates from US EPA's Generator Improvements Rule. Also coming to Oregon: New management standards for hazardous waste pharmaceuticals, aerosols as universal waste and more. The new regulations take effect January 1, 2022.

Update 06/14/21 
has adopted the RCRA Hazardous Waste Generator Improvements Rule. A Notice of Final Action was published to the Maryland Register issued on April 23, 2021 (pp. 359—360). When the rule was proposed, Maryland DOE released a two-page document detailing critical hazardous waste regulatory changes. Effective date: May 3, 2021.   

Update 04/30/21
Tennessee has adopted the RCRA Generator Improvements Rule, along with other Federal hazardous waste rule updates. Effective date: May 13, 2021. 

Update 01/21/20
Effective January 21, 2021, Delaware has adopted the RCRA Generator Improvements Rule. New regulations concerning aerosols as universal waste, hazardous waste pharmaceuticals, waste airbags, hazardous waste import/export, and electronic Manifests are in effect now in Delaware too.  

Update 01/13/20
Nevada adopted the Generator Improvements Rule in 2020, Lion has learned. The updated hazardous waste regulations were signed into law on August 25, 2020.

Update 11/18/20 
As of October 2, 2020, Arkansas has adopted five recent RCRA rule updates, including the Generator Improvements Rule, into state Regulation 23. The state's Pollution Control and Ecology Commission (APC&EC) notified stakeholders of the rulemaking by e-mail this week. 

Update 10/05/20
Michigan, Ohio, and Wisconsin have all incorporated the RCRA Generator Improvements Rule into their state hazardous waste regulations. Effective dates:
  • Michigan: August 3, 2020 (Details)
  • Wisconsin: September 1, 2020 (Details)
  • Ohio: October 5, 2020 (Details)
Update 7/28/20
Louisiana and North Dakota each adopted the updates in EPA's Generator Improvements Rule in July 2020,

Update 5/19/20 
Indiana and Wyoming are the two states to most recently adopt EPA's Generator Improvements Rule. That means half the country (25 states) have now adopted the more stringent RCRA requirements. 

What is the Generator Improvements Rule?

The effective date for US EPA’s landmark Generator Improvements Rule (GIR) was May 30, 2017.

States with approved RCRA programs (i.e., all states other than Alaska and Iowa) must adopt at least the more-stringent regulations within one year of the Final Rule’s effective date. If a state needs to change its state law to accommodate changes to its hazardous waste program, the state gets two years to adopt the Generator Improvements Rule.

Both the one-year and two-year deadlines have now passed. If your state has not yet adopted the mandatory elements of the Generator Improvements Rule, you should expect them to very soon. 

How the Generator Improvements Rule Makes RCRA Stricter

The following are examples (not all-inclusive) of more stringent requirements from EPA's Generator Improvements Rule:

Waste Determinations

  1. The recordkeeping and retention requirements for hazardous waste determinations previously found at 40 CFR section 262.40(c) were moved into section 262.11(f), with clarifications on what records must be kept;
  2. Small and Large quantity generators must indicate waste codes on containers before shipping hazardous waste off site to a RCRA permitted treatment, storage, and disposal facility in accordance with the requirements of 40 CFR section 262.32; and
  3. Any generator managing a potentially hazardous waste should manage it in accordance with the generator regulations until such time that the generator is sure that the waste is not hazardous (e.g. while awaiting the results of analysis).

Marking and Labeling

The final rule added a provision for generators to mark hazardous waste containers with an indication of the hazards of the contents.

Emergency Preparedness and Prevention

The GIR added a requirement that the generator must keep documentation of the fact that it has made arrangements with local emergency responders.

LQG’s written contingency plan must include satellite accumulation areas and have a “quick reference guide.”


There are new closure reporting requirements for a large quantity generator’s 90-day central storage area.


Small quantity generators will be required to re-notify starting in 2021 and every four years thereafter using EPA Form 8700-12. This re-notification must be submitted by September 1st of each year in which re-notifications are required.

Watch your State Registers for official notification of when the GIR has been adopted in your state, keep an eye on Lion News for more updates in the future, or visit the EPA website for a list of state adoption activities.

If Your State Has Adopted the GIR... 

If your state is pictured in blue on the map above, check your state regulations to see if they adopted the GIR in its entirety.

States are not required to adopt anything that is less stringent then their current regulations.
New RCRA rules that are less stringent include:
  1. Allowing a hazardous waste generator to avoid increased burden of a higher generator status when generating episodic waste provided the episodic waste is properly managed
  2. Allowing a very small quantity generator (VSQG) to send its hazardous waste to a large quantity generator under control of the same person
  3. Venting containers at satellite areas for certain conditions
  4. Removing the need for the home address of Emergency Coordinators
To check your updated state regulations, click here and scroll to your state for the link: Links to Generator Improvements State Regulations.

What if My State Did Not Adopt the GIR Yet?

In states that have not yet adopted the Generator Improvements Rule, Lion recommends that generators comply with the stricter regulations. 

In the US, hazardous waste regulation is a joint effort between Federal and state agencies. When US EPA makes changes to the Federal program, states must adopt any updates that make the rules more stringent. States that fail to maintain hazardous waste regulations that are at least as stringent as the Federal RCRA program risk losing their authorization to run a state program.

Did we miss your state? Know something we should add to the next update?
Email and we’ll take a look!

Get RCRA Training—When You Want, Where You Want

hazardous waste storageUS EPA requires hazardous waste professionals to complete annual training on the RCRA requirements. Lion makes it easy to meet your RCRA training mandate in a variety of formats—nationwide public workshops, convenient online courses, live webinars, and on-site training.

Browse RCRA training options here to find the course that fits your needs, your schedule, and your learning style.

Lion - Quotes

"The instructor does a great job at presenting material in an approachable way. I have been able to save my company about $30,000 in the last year with what I have learned from Lion!"

Curtis Ahonen

EHS&S Manager

"These are the best classes I attend each year. I always take something away and implement improvements at my sites."

Kim Racine

EH&S Manager

"Lion is easily and consistently the best option for compliance training. I've learned new information from every instructor I've had."

Rachel Mathis

EHS Specialist

"Attending Lion Technology classes should be mandatory for every facility that ships or stores hazmat. "

Genell Drake

Outbound Lead

"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

"The instructor had knowledge of regulations and understanding of real-world situations. The presentation style was engaging and fostered a positive atmosphere for information sharing."

Linda Arlen

Safety & Environmental Compliance Officer

"As always, Lion never disappoints"

Paul Resley

Environmental Coordinator

"I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for."

Frank Sizemore

Director of Regulatory Affairs

"I was recently offered an opportunity to take my training through another company, but I politely declined. I only attend Lion Technology workshops."

Stephanie Gilliam

Material Production/Logistics Manager

"Excellent. I learned more in two days with Lion than at a 5-day program I took with another provider."

Francisco Gallardo

HES Technician

"The instructor was excellent. They knew all of the material without having to read from a notepad or computer. "

Gary Hartzell

Warehouse Supervisor

"I attended training from another provider and learned absolutely nothing. Lion is much better. Hands down."

Nicole Eby

Environmental Specialist

"This training broke down the regulations in an easy-to-understand manner and made them less overwhelming. I now feel I have the knowledge to make more informed decisions."

Amanda Oswald

Shipping Professional

"This is the best RCRA training I've experienced! I will be visiting Lion training again."

Cynthia L. Logsdon

Principal Environmental Engineer

"I have attended other training providers, but Lion is best. Lion is king of the hazmat jungle!!!"

Henry Watkins

Hazardous Waste Technician

"I can't say enough how pleased I was with this course! Everything finally makes sense."

Kim Graham

Lab Manager

"The instructor was energetic and made learning fun compared to dry instructors from other training providers."

Andy D’Amato

International Trade Compliance 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

"I have been to other training companies, but Lion’s material is much better and easier to understand."

Mark Abell

Regional Manager

"I love that the instructor emphasized the thought process behind the regs."

Rebecca Saxena

Corporate Product Stewardship Specialist

"More thorough than a class I attended last year through another company."

Troy Yonkers

HSES Representative

"Amazing instructor; real-life examples. Lion training gets better every year!"

Frank Papandrea

Environmental Manager

"The instructor clearly enjoys his job and transmits that enthusiasm. He made a dry subject very interesting and fun."

Teresa Arellanes

EHS Manager

"I can take what I learned in this workshop and apply it to everyday work and relate it to my activities."

Shane Hersh

Materials Handler

"The instructor was probably the best I ever had! He made the class enjoyable, was humorous at times, and very knowledgeable."

Mary Sue Michon

Environmental Administrator

"The instructor was great, explaining complex topics in terms that were easily understandable and answering questions clearly and thoroughly."

Brittany Holm

Lab Supervisor

"These are the best commercial course references I have seen (10+ years). Great job!"

Ed Grzybowski

EHS & Facility Engineer

"Excellent job. Made what is very dry material interesting. Thoroughly explained all topics in easy-to-understand terms."

David Hertvik

Vice President

"You blew the doors off the competition!"

Stephen Bieschke

Facilities Manager

"I like Lion's workshops the best because they really dig into the information you need to have when you leave the workshop."

Tom Bush, Jr.

EHS Manager

"Best course instructor I've ever had. Funny, relatable, engaging; made it interesting and challenged us as the professionals we are."

Amanda Schwartz

Environmental Coordinator

"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

"Lion Technology workshops are amazing!! You always learn so much, and the instructors are fantastic."

Dorothy Rurak

Environmental Specialist

"If I need thorough training or updating, I always use Lion. Lion is always the best in both instruction and materials."

Bryce Parker

EHS Manager

"I appreciate the focus on what the regulations tell us to do, as well as what is subject to interpretation."

Nicole Eby

Environmental Specialist

"The exercises in the DOT hazardous materials management course are especially helpful in evaluating your understanding of course information."

Morgan Bliss

Principal Industrial Hygienist

"Excellent course. Very interactive. Explanations are great whether you get the questions wrong or right."

Gregory Thompson

Environmental, Health & Safety Regional Manager

"I used the IT support number available and my issue was resolved within a few minutes. I don't see anything that could have made it better."

Danny Province

EHS Professional

"Content was comprehensive and seemed to really “dig in” to the material. I liked the option to review FAQs and re-review the quiz questions."

Morgan Bliss

Principal Industrial Hygienist

"The price was reasonable, the time to complete the course was manageable, and the flexibility the online training allowed made it easy to complete."

Felicia Rutledge

Hazmat Shipping Professional

"The course is well thought out and organized in a way that leads to a clearer understanding of the total training."

David Baily

Hazmat Shipping Professional

"This is a very informative training compared to others. It covers everything I expect to learn and even a lot of new things. "

Quatama Jackson

Waste Management Professional

"The training was impressive. I am not a fan of online training but this was put together very well. I would recommend Lion to others."

Donnie James

Quality Manager

"My experience with Lion training, both online and in the classroom, is that they are far better organized and provide a better sequential explanation of the material."

Robert Roose

Manager, Dangerous Goods Transportation

"Very well structured, comprehensive, and comparable to live training seminars I've participated in previously. I will recommend the online course to other colleagues with training requirement needs."

Neil Luciano

EHS 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

"Lion is at the top of the industry in compliance training. Course content and structure are updated frequently to make annual re-training enjoyable. I like that Lion has experts that I can contact for 1 year after the training."

Caroline Froning

Plant Chemist

"The course was very well structured and covered the material in a clear, concise manner."

Ian Martinez

Hazmat Shipping Professional

"The online course was well thought out and organized, with good interaction between the student and the course."

Larry Ybarra

Material Release Agent

"My experience with Lion classes has always been good. Lion Technology always covers the EPA requirements I must follow."

Steven Erlandson

Environmental Coordinator

"I had a positive experience utilizing this educational program. It was very informative, convenient, and rewarding from a career perspective."

John Gratacos

Logistics Manager

"Lion does a great job summarizing and communicating complicated EH&S-related regulations."

Michele Irmen

Sr. Environmental Engineer

"Far superior in terms of detail and instructional/support materials. The depth of instructor knowledge is always beyond any other training I have participated in."

Linda Arlen

Safety & Environmental Compliance Officer

"The instructor was very knowledgeable and provided pertinent information above and beyond the questions that were asked. "

Johnny Barton

Logistics Coordinator

"I have returned to Lion's compliance training for several years and prefer to stay with a trusted source. The material and presentation are far superior than others I have taken."

Robert Roose

Manager, Dangerous Goods Transportation

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

Jeremy Bost

Environmental Health & Safety Technician

"Lion's information is very thorough and accurate. Presenter was very good."

Melissa Little

Regulatory Manager

"Lion courses always set the bar for content, reference, and practical application. Membership and access to the experts is an added bonus."

John Brown, CSP

Director of Safety & Env Affairs

"The instructor's energy, enthusiasm, and knowledge of the subject make the class a great learning experience!"

Brian Martinez

Warehouse Operator

"Excellent class, super instructor, very easy to follow. No rushing through material. Would like to take his class again."

Lawrence Patterson

EH&S Facility Maintenance & Security Manager

"I think LION does an excellent job of any training they do. Materials provided are very useful to my day-to-day work activities."

Pamela Embody

EHS Specialist

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

Amanda Walsh

Hazardous Waste Professional

"Lion was very responsive to my initial questions and the website was user friendly."

Michael Britt

Supply Chain Director

"Convenient; I can train when I want, where I want."

Barry Cook

Hazmat Shipping Professional

"Having the tutorial buttons for additional information was extremely beneficial."

Sharon Ziemek

EHS Manager

"We have a very busy work schedule and using Lion enables us to take the course at our own time. It makes it easy for me to schedule my employees' training."

Timothy Mertes

Hazmat Shipping Professional

"Lion's course was superior to others I have taken in the past. Very clear in the presentation and the examples helped to explain the content presented."

George Bersik

Hazardous Waste Professional

"Lion courses are the standard to which all other workshops should strive for!"

Brody Saleen

Registered Environmental Health Specialist

"Course instructor was better prepared and presented better than other trainers. Course manual and references were easier to use as well."

Marty Brownfield

Hazardous Waste Professional

"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

"Our instructor was very dynamic and kept everyone's interest. Hazmat shipping can be a dry, complicated topic but I was engaged the entire time."

Kimberly Arnao

Senior Director of EH&S

"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

"I was able to present my scenario to the instructor and worked thru the regulations together. In the past, I attended another training firm's classes. Now, I have no intention of leaving Lion!"

Diana Joyner

Senior Environmental Engineer

"The workshop covered a lot of information without being too overwhelming. Lion is much better, more comprehensive than other training providers."

George Alva

Manufacturing Manager

"The instructor did an excellent job presenting a very dry subject; keeping everyone interested and making it enjoyable."

Marc Bugg

Hazardous Waste Professional

"Well designed and thorough program. Excellent summary of requirements with references. Inclusion of regulations in hard copy form, as well as full electronic with state pertinent regulations included is a great bonus!"

Oscar Fisher

EHS Manager

"Very witty instructor, made the long times sitting bearable. One of the few training courses I can say I actually enjoyed."

John Hutchinson

Senior EHS Engineer

"The instructor made the class enjoyable. He presented in a very knowledgeable, personable manner. Best class I've ever attended. Will take one again."

John Nekoloff

Environmental Compliance Manager

"The instructor was very engaging and helped less experienced people understand the concepts."

Steve Gall

Safety Leader

"This was the 1st instructor that has made the topic actually enjoyable and easy to follow and understand. Far better than the "other" training providers our company has attended!"

Lori Hardy

Process & Resource Administrator

"I really enjoyed this training. Even after years on both sides of the comprehension coin, I find myself still learning! The quality of the delivery exceeded much of the training I have received in the past."

Neil Ozonur

Safety Officer

"The instructor created a great learning environment."

Avinash Thummadi

CAD & Environmental Manager

"Lion's training was by far the best online RCRA training I've ever taken. It was challenging and the layout was great!"

Paul Harbison

Hazardous Waste Professional

"The instructor took a rather drab set of topics and brought them to life with realistic real-life examples."

Tom Berndt

HSE Coordinator

"Given the choice, I would do all coursework this way. In-person courses go very fast without the opportunity to pause or repeat anything."

Ellen Pelton

Chemical Laboratory Manager

"I really enjoy your workshops. Thank you for such a great program and all the help Lion has provided me over the years!"

George Chatman

Hazardous Material Pharmacy Technician

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

Kevin Pylka

Permitting, Compliance & Environmental Manager

"No comparison. Lion has the best RCRA training ever!!"

Matt Sabine

Environmental Specialist

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

John Troy

Environmental Specialist

"The instructor was very very informative, helpful, understandable and pleasant. This course answered many questions I had, being new to this industry."

Frances Mona

Shipping Manager

"I will never go anywhere, but to Lion Technology."

Dawn Swofford

EHS Technician

"Lion provided an excellent introduction to environmental regulations, making the transition to a new career as an EHS specialist less daunting of a task. Drinking from a fire hose when the flow of water is lessened, is much more enjoyable!"

Stephanie Weathers

SHE Specialist

"One of the best trainings I have ever received!"

Brandon Morfin

EH&S Manager

"Best instructor ever! I was going to take my DOT training w/a different provider, but based on this presentation, I will also be doing my DOT training w/Lion!"

Donna Moot

Hazardous Waste Professional

"Lion was very extensive. There was a lot of things that were covered that were actually pertaining to what I do and work with. Great Job. I will be coming back in three years! "

Tony Petrik

Hazmat Shipping Professional

"The instructor made the class very enjoyable and catered to the needs of our group."

Sarah Baker


"The instructor was very patient and engaging - willing to answer and help explain subject matter."

Misty Filipp

Material Control Superintendent

"Much better than my previous class with another company. The Lion instructor made sense, kept me awake and made me laugh!"

Marti Severs

Enterprise Safety Manager

"Lion is my preferred trainer for hazmat and DOT."

Jim Jani

Environmental Coordinator

download our latest whitepaper

Find out which tanks and substances are regulated under EPA’s Underground Storage Tank (UST) program. Plus, find out which common exclusions are no longer required for tank owners and operators after October 2018.

Basics of Underground Storage Tank Compliance

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 Current and Privacy Policy.