Tennessee Adopts RCRA Generator Improvements, Other Major Updates

Posted on 4/26/2021 by Roger Marks

Effective May 13, 2021, the state of Tennessee will incorporate major changes to the RCRA hazardous waste requirements into its state regulations.

Most notably, Tennessee will adopt EPA’s Generator Improvements Rule (GIR), which overhauled the Federal RCRA hazardous waste regulations to add more stringent requirements for container labels, contingency planning, EPA notification and re-notification, hazardous waste recordkeeping, and more.

The GIR also re-organized the generator regulations in 40 CFR Part 262 and added some new reliefs, including an exception for episodic events (e.g. spills, lab clean outs) that generate hazardous waste.

Airbag Waste, e-Manifest User Fees, & More

In addition to the Generator Improvements, Tennessee will adopts four other Federal rulemakings completed between November 2016 and November 2018 with this action. These four RCRA rules:
  • Exempt airbag waste from hazardous waste requirements, under certain conditions, to facilitate removal and safe disposal of defective airbag inflators by dealerships, salvage yards, and others, 

  • Implement regulations to establish user fees applicable to the electronic hazardous waste Manifest (e-Manifest) system,   

  • Disallow claims of business confidentiality with respect to export documentation of cathode ray tubes (CRTs), and  

  • Require electronic submission of notices concerning hazardous waste export and import.
Read a summary of the rule updates that take effect May 13 here.

Get up to speed next month! Lion’s two-day RCRA Hazardous Waste Management Webinar guides you through the latest RCRA hazardous waste regulations, including major changes in the Generator Improvements Rule. Help satisfy EPA’s annual training mandate at this live, expert-led webinar on May 12—13.

Next Up: Aerosol Cans and Ignitable Hazardous Waste ID

In a second rulemaking, which is set to take effect on June 3, 2021, Tennessee will also:
  • Allow hazardous waste aerosol cans to be managed as universal waste; and  

  • Update the rules and modernize the test methods for identifying ignitable hazardous wastes. 
Read a summary of the rule updates that take effect June 3 here.

EPA’s Final Rule to add aerosol cans that contain a hazardous waste to the universal waste program took effect in February 2020. When managed properly, universal wastes are granted relief from some of the more burdensome RCRA hazardous waste management requirements. Adding hazardous waste aerosol cans to the universal waste program will offer potential cost savings for generators in Tennessee.

In July 2020, US EPA finalized a rulemaking to “modernize” the test requirements for ignitable hazardous wastes. The rule does not change the classification criteria for ignitable hazardous wastes. It does, however, update the flash point testing methods in 40 CFR 260.11 to allow the use of non-mercury thermometers.

In the past, only mercury thermometers were allowed. This gives generators more, safer options for testing wastes for ignitability.  The rule also codifies existing EPA guidance regarding the exclusion for aqueous solutions.

Up to Date RCRA Training to Keep Your Site in Compliance

At, find live RCRA training for new and experienced personnel to get everyone up to speed on the regulations they must know to safely manage hazardous waste and help avoid accidents, injuries, and costly fines and penalties.

RCRA Hazardous Waste Management Webinar
May 12–13

Develop the in-depth expertise you need to identify regulated wastes and meet your responsibilities for proper storage, labeling, and safe disposal at this two-day RCRA webinar. 

RCRA Hazardous Waste Management Refresher Webinar
May 4 and May 18

Help satisfy EPA's annual RCRA training mandate with this streamlined, one-day course for experienced hazardous waste professionals. 

Tags: hazardous waste management, RCRA, Tennessee

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