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RCRA Generator Improvements Rule Remains on Track

Posted on 1/31/2017 by Roger Marks

EPA’s major overhaul of the Resource Conservation and Recovery Act (RCRA) is set to take effect in May 2017. Originally published in November 2016, this Final Rule is not impacted by the recent freeze on new EPA regulations and will take effect as scheduled.

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.

RCRA hazardous waste trainingTo 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.

RCRA Generator Improvements: EPA Hazardous Waste Enforcement Policy

Executive Summary: EPA is clarifying a key part of hazardous waste enforcement policy in the Generator Improvements Rule. The Agency differentiates between “independent requirements” of RCRA and the “conditions for exemption.” 

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.

RCRA Generator Improvements: EPA Moves RCRA Training Standard

Executive Summary: As part of a wholesale reorganization of the RCRA rules, US EPA will relocate the training requirements for hazardous waste personnel:

  • 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.

RCRA Generator Improvements: EPA OK’s Online Hazardous Waste Training

EPA allows online hazardous waste training
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.



This week! RCRA Generator Improvements Rule Update Webinar - $99 for Lion Members

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.

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. 

Tags: EPA, hazardous waste, new rules, RCRA

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