RCRA Reporting Requirements to Be Extended

Posted on 2/26/2018 by Roger Marks

US EPA today proposed an extension of an “information collection request,” or ICR, that requires hazardous waste generators, contractors, and others to keep records related to the recycling of hazardous secondary materials. 
This action would extend paperwork requirements that originate from a January 2015 Final Rule that revised EPA’s Definition of Solid Waste to exclude certain hazardous secondary materials from regulation under RCRA. In addition to new exclusions, the Final Rule added recordkeeping rules EPA says ensure regulated entities meet their responsibilities and help inspectors verify compliance. 
The information requirements proposed for extension impact generators, verified recyclers, contractors, and others involved in shipping, transporting, and recycling hazardous secondary materials under the exclusions added in the 2015 Final Rule. These exclusions are found at 40 CFR 261.4(a)(23), (24), and (27), and the revised speculative accumulation requirement at 40 CFR 261.1(c)(8). 


The specific requirements affected by today’s ICR request include shipping records and receipts, financial assurance requirements, personnel training, labeling storage containers, and emergency preparedness and response conditions. These information requests were set to expire in April of this year.
These hazardous secondary materials recycling paperwork requirements impact about 200 entities, who spend about 37,000 hours and $2,400,000 per year to comply, according to the proposed rule. 
EPA will accept comments on the ICR extension for sixty days under Docket ID No. EPA-HQ-OLEM-2018-0013 at or by e-mail to or mail. 

What Is an ICR?

Paperwork: It’s a big part of being a “regulated entity.” The government requires businesses of all kinds to keep all sorts of records, for all sorts of reasons. For hazardous waste generators, this can mean personnel training records, waste determination records, Manifests, recycling and treatment paperwork, and more. 
To prevent paperwork requirements from getting out of control (in theory), US law requires Federal Agencies to periodically justify the existence of each paperwork burden they put on business. 

Advanced RCRA in Salt Lake City! March 14.

rcra_recycling_newsletter.jpgThe Advanced RCRA Hazardous Waste Management Workshop brings together experienced environmental professionals to explore methods to minimize waste, control pollution, and find relief from burdensome RCRA requirements.

Join your peers to discover new ways to cut costs without running afoul of the hazardous waste regulations and limit your exposure to liability under programs like CERCLA.
Don’t miss the Advanced RCRA workshop when it comes
to Salt Lake City for the only time this year, on March 14.

Learn the New RCRA Rules

From stricter contingency planning and reporting responsibilities to updated container labeling rules, re-organized generator regulations, new reliefs, and more—find out what to expect when your state adopts EPA’s “Generator Improvements Rule.”

You will leave with answers and resources that simplify the day-to-day job of environmental compliance. Sign up now. 

Tags: EPA, hazardous waste, RCRA, RCRA recycling, reporting and recordkeeping

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