Changes to RCRA Hazardous Waste Generator Regulations

Posted on 7/6/2015 by Roger Marks

The United State Environmental Protection Agency (EPA) plans to propose changes to the RCRA hazardous waste generator regulations this month (July 2015). Named the Hazardous Waste Generator Improvements Rule, the forthcoming proposed rule “will suggest changes to the RCRA hazardous waste regulations to improve the effectiveness and clarity of the generator rules.”

What’s Planned for the New RCRA Generator Rules?

Provided as part of EPA’s Spring Regulatory Agenda printed in the Federal Register on June 18, the rule abstract lists a number of changes for generators, including:
  • Consolidating the hazardous waste generator regulations in part 262 of Title 40 of the Code of Federal Regulations (40 CFR);
  • Requiring additional information on hazardous waste container labels for large and small quantity generators; and
  • Setting streamlined rules that allow generators to maintain their “generator status” even when an episodic event causes them temporarily to move into a higher regulatory status.
Episodic Generation of RCRA Hazardous Waste

The last item on the list above addresses an issue that can cause some generators distress. Under the current RCRA regulations, a “large quantity generator”—a site that generates 1000 or more kg of hazardous waste per month—is subject to the most stringent management and storage standards.

Small quantity generators and conditionally exempt generators typically manage smaller quantities of waste, and therefore are subject to less-stringent management standards than their “large quantity” counterparts. However, a one-time event like a lab cleanout or an on-site spill can result in more than 1000 kg of waste generated in a particular month.

RCRA waste managers prepare for new rules from US EPA

When this happens, the site suddenly must comply with the more stringent Large Quantity Generator rules—including having a written contingency plan that includes arrangements with local emergency response authorities (police, fire, hospitals), a written training plan, and employee training records.

In other words, these one-time, “episodic” generator events can cause a site to fall out of compliance, without meaning to, and be responsible for meeting requirements they were never subject to as a small or conditionally exempt generator. A new rule would help environmental managers that may find themselves scrambling to comply when a one-time generation event pushes them over the limit for their current regulatory status.

EPA’s Hazardous Waste Generator Improvements Rule proposal has been under review by the Office of Management and Budget (OMB) since March of this year. The Rule Identification Number (RIN) for the rulemaking is 2050-AG70.

Expert RCRA Training for Managers and Personnel

Lion Technology helps industry comply with changing RCRA hazardous waste; hazmat shipping; and EPA air, water, and chemical rules. Lion presents workshops in 65+ US cities, led by expert instructors who engage with their audience and promote discussion to clarify these complex standards. Convenient online courses and webinars make it easy for managers and employees to keep up to date with the latest rules, and know what they must do to comply. To learn more about training options for your business, visit

Subscribe to Lion News for More

Subscribe to Lion News for updates on the latest RCRA hazardous waste regulations that affect your business. When this proposed rule appears in the Federal Register, Lion will be ready to help generators comply with any new requirements with exclusive content and convenient, effective RCRA training.

Tags: EPA, hazardous waste, new rules, RCRA

Find a Post

Compliance Archives

Lion - Quotes

Best instructor ever! I was going to take my DOT training w/a different provider, but based on this presentation, I will also be doing my DOT training w/Lion!

Donna Moot

Hazardous Waste Professional

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

Lion does a great job summarizing and communicating complicated EH&S-related regulations.

Michele Irmen

Sr. Environmental Engineer

No comparison. Lion has the best RCRA training ever!!

Matt Sabine

Environmental Specialist

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

Troy Yonkers

HSES Representative

The instructor kept the class engaged and made learning fun. There was a lot of information to cover but time flew by. I will definitely use Lion in the future!

Chelsea Minguela

Hazmat Shipping Professional

Lion's course was superior to others I have taken in the past. Very clear in the presentation and the examples helped to explain the content presented.

George Bersik

Hazardous Waste Professional

Having the tutorial buttons for additional information was extremely beneficial.

Sharon Ziemek

EHS Manager

This is the best RCRA training I've experienced! I will be visiting Lion training again.

Cynthia L. Logsdon

Principal Environmental Engineer

The course was very informative and presented in a way that was easily understood and remembered. I would recommend this course.

Jeffrey Tierno

Hazmat Shipping Professional

Download Our Latest Whitepaper

Hazardous materials shipment rejections bear a big cost. Use this guide to end operational and logistical disruptions that severely impact your bottom line.

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.