CA Generator Improvements FAQ: Re-Notification Requirements
California DTSC recently released an FAQ to help hazardous waste generators comply with revised and re-organized regulations that took effect on July 1, 2024.
"FAQ" #4 on the California GIR page relates the purpose and requirements of re-notification, how generators must submit re-notification to DTSC, and how re-notification requirements affect DTSC’s electronic Verification Questionnaire (eVQ) requirements.
View the FAQ on DTSC's website.
1. What is the purpose of re-notification?
According to U.S. EPA the purpose of the re-notification requirement is to improve the SQG universe data and to maintain more accurate data into the future for outreach, compliance assistance and oversight activities.
2. Do re-notification requirements apply to generators that only generate non-RCRA hazardous waste?
No, re-notification requirements don’t apply to generators that only generate non-RCRA hazardous waste.
Re-notification requirements only apply to RCRA hazardous waste generators. For example, an automotive repair facility that generates only used oil, waste antifreeze and non-listed-solvent parts wash solutions (along with core exchanged batteries and laundered rags) is not required to re-notify, because these wastes are non-RCRA (California only) hazardous waste.
3. When and how must generators submit their re-notification to DTSC?
Re-notifications must be submitted as follows:
LQGs of RCRA hazardous waste must re-notify DTSC by March 1 of each even-numbered year starting in 2026 using U.S. EPA form 8700-12. LQGs can submit the U.S. EPA form 8700-12 re-notification as part of their Biennial Report (i.e. U.S. EPA Form 8700 13A/B) submission.
SQGs of RCRA hazardous waste must re-notify DTSC every four years starting 2024, using U.S. EPA form 8700-12. Re-notification for SQGs is due by September 1 of each year in which re-notification is required.
Generators may use U.S EPA’s RCRAInfo system to electronically submit re-notifications to DTSC.
4. Are generators still required to annually submit hazardous waste information to DTSC’s electronic Verification Questionnaire (eVQ) system if they are also required to submit a re-notification to DTSC?
The requirement for generators to annually verify their hazardous waste information using the eVQ system and the requirement for generators to re-notify DTSC are two separate requirements. Per Health & Safety Code section 25205.16, entities (including LQGs and SQGs) that have been issued a U.S. EPA Identification (ID) Number are required to annually verify the accuracy of the hazardous waste information associated with the ID number using the eVQ system. Additionally, LQGs and SQGs are required to submit a re-notification to DTSC using U.S. EPA form 8700-12 by the applicable due date.
Lion Members can see a more extensive breakdown of the changes that came with California's adoption of the GIR in the 4-page exhibit added to Lion.com/Members.
Expert-led Title 22/RCRA Refresher Training
Training with Lion in 2024 gives you an extra advantage: Lion instructors are well-versed in the RCRA Generator Improvements and how they affect generators in California. Lion has been updating and refining our hazardous waste training programs to address the new requirements since US EPA enacted them nearly a decade ago.
Check the schedule of upcoming instructor-led training (workshops and live webinars) to get up to speed before the new, stronger standards take effect.
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