RCRA Generator Improvements Rule Remains on Track
Among the biggest changes in the Generator Improvements Rule are:
- The wholesale re-organization of 40 CFR 262.
- Expanded emergency preparedness requirements.
- Bolstered rules for biennial reporting.
- A new relief for episodic generation events that impact a facility’s generator status.
- New marking and labeling requirement for hazardous waste tanks and containers.
To help EHS managers prepare for these and other changes in the Final Rule, today we’ve compiled some of the most popular features about the Generator Improvements Rule we’ve published in the past few months. Below we’ve provided links to these features, along with an executive summary for each one.
Most generator sites are “exempt” from the most burdensome RCRA requirements—those reserved for treatment, disposal, and storage facilities, or TSDFs. That said, to maintain this “exemption,” generators must meet certain conditions.
If a condition for exemption is not met, the generator may be held liable for violations as if it were a TSDF. This could mean fines for failure to have a RCRA permit, to follow more stringent training rules, to maintain a written contingency plans, and to follow other requirements from which small generators are typically exempt.
- For large quantity generators, the training requirements are moving from 40 CFR 262.34(a) and 265.16 to a new section 262.17.
- For small quantity generators, the RCRA training rules are moving from 40 CFR 262.34(d)(5)(iii) to a new section 262.16.
- For conditionally exempt small quantity generators (CESQGs)—to be referred to as “Very Small Quantity Generators” under the revised RCRA rules—management standards will now be found in 40 CFR 262.14. RCRA training is not explicitly required for personnel at Very Small Quantity Generator facilities.
Executive Summary: EPA has added computer-based or online training to the list of approved methods for training hazardous waste personnel. EPA recognizes that many EHS professionals already use online options to help satisfy EPA’s annual hazardous waste training standard and will therefore add this method to new sections in 40 CFR, 262.16 and 262.17.
Now that EPA’s Generator Improvements Rule is finalized, professionals responsible for hazardous waste management will face questions from colleagues and higher-ups about what must be done to stay in compliance. The new RCRA update webinar will give managers and personnel the answers they need to prepare and plan for big changes to these complex EPA standards.
This week! RCRA Generator Improvements Rule Update Webinar - $99 for Lion Members
The next session will be presented on February 7 from 1:00-2:30 p.m. ET. Two additional sessions will follow on February 28 and March 23.
Current Lion Members can attend the webinar for $99. Those without a current Lion Membership can attend for $129. Attendance includes live, expert-led training; a digital compliance reference; and a Certificate of Attendance.
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.
Senior Director of EH&S
Lion's training was by far the best online RCRA training I've ever taken. It was challenging and the layout was great!
Hazardous Waste Professional
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.
Lion is my preferred trainer for hazmat and DOT.
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.
Director of Regulatory Affairs
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.
Hazmat Shipping Professional
The instructor was excellent. They knew all of the material without having to read from a notepad or computer.
The instructor created a great learning environment.
CAD & Environmental Manager
The workshop covered a lot of information without being too overwhelming. Lion is much better, more comprehensive than other training providers.
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.
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Use this guide as a quick reference to the most common HAZWOPER questions, and get course recommendations for managers and personnel who are in need of OSHA-required HAZWOPER training.