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 Those comments led EPA to revise and clarify some of the withdrawn provisions before republishing them recently.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

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

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

Steve Gall

Safety Leader

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

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

Barry Cook

Hazmat Shipping Professional

You blew the doors off the competition!

Stephen Bieschke

Facilities Manager

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 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

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

Troy Yonkers

HSES Representative

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

Henry Watkins

Hazardous Waste Technician

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

Ed Grzybowski

EHS & Facility Engineer

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.