Cal DTSC Generator Improvements Updates Proposed

Posted on 3/24/2023 by Roger Marks

California’s Department of Toxic Substances Control (DTSC) has proposed a rule to adopt several more-stringent provisions for hazardous waste generators from US EPA’s Generator Improvements Rule into the state’s regulations.

A 45-day public comment period opened on Friday, March 24 and closes on May 8. Hazardous waste generators, industry stakeholders, and the general public can submit written comments in two ways: 

•    Email written comments to 
•    Mail hard-copy written comments to:

Office of Legislation and Regulatory Review 
Department of Toxics Substances Control 
P.O. Box 806, Sacramento, CA 95802-0806 

Cal DTSC Generator Improvements Updates Proposed

Which New RCRA Rules Will DTSC Adopt?

DTSC has stated that the proposed rule released on Friday, March 24 is "Phase 1" of the agency's plan to adopt provisions from the Generator Improvements Rule. This proposed rule adds new and strengthened RCRA standards that are more-stringent than California's current regulations/laws.

The seven "more-stringent" provisions, which are mandatory for the state to adopt to maintain authorization under RCRA, are:

  1. New re-notification requirements for generators
  2. New labeling and marking requirements for hazardous waste containers
  3. New pre-transportation marking requirements 
  4. New large quantity generator closure requirements 
  5.  Additional requirements for incompatible wastes in satellite accumulation areas 
  6. New requirements added to the preparedness, prevention, and emergency procedures for small quantity generators and large quantity generators including:
    1.  Documenting that arrangements with local authorities were made or attempted to be made by the generator; and
    2. A Quick Reference Guide that summarizes a large quantity generator's contingency plan 
  7.  Additional requirements for containers holding ignitable and reactive wastes for large quantity generators. 

For details about submitting public comments, the full proposed regulatory text, regulators' reasoning for the rule, and more, visit the dedicated webpage on DTSC's website. 

Re-organized Regulations 

In addition to adding stricter requirements for generators, the proposed rule will re-organize California's hazardous waste regulations in Title 22 of the Code of California Regulations (22 CCR). The standards for large and small quantity generators, and the satellite accumulation rules, will be moved to 66262.17, 66262.16, and 66262.15 respectively

This change matches EPA's re-location of generator rules in RCRA—moving them out of the TSDF standards in 40 CFR Part 265 and into 40 CFR Part 262. 

California is also proposing to move the preparedness and prevention requirements and contingency and emergency procedures to a new Article 9 within 22 CCR Division 4.5, Chapter 12. 

From DTSC's Proposed Rule: 

California’s hazardous waste regulations parallel federal hazardous waste regulations in many respects, including organizational structure. Therefore, the proposed regulations align with the federal regulation organizational changes. Specific reorganizations are detailed in the Initial Statement of Reasons (ISOR) document.

California’s hazardous waste program is broader in scope than that of U.S. EPA because the requirements apply to generators of non-RCRA hazardous wastes. The proposed regulations apply many, but not all, of the GIR changes to both RCRA and non-RCRA hazardous waste generators in California.

What About Phase 2?

In a second rulemaking later this year ("Phase 2"), DTSC may adopt some new reliefs for generators also found in the Improvements Rule. This includes an exemption for hazardous waste generated by "episodic events," revisions to the satellite area rules, and more. 

For more detail on new requirements added to RCRA with the Generator Improvements, check out our GIR summary post that includes updates on state adoption around the US and a color-coded map of which states have adopted the new rules so far: Where is the Generator Improvements Rule in Effect Now?

Next RCRA/Title 22 Trainings for Waste Pros in California 

Workshops in L.A. and San Diego Areas

At the California Hazardous Waste Management Workshops in San Diego and Ontario, California in May 2023, your instructor will call attention to state regulations that will change when California adopts mandatory stricter provisions and re-organized the state hazardous waste regulations. 

Ontario, CA May 8–9
San Diego, CA       May 15–16  

Workshops return to L.A., with a stop in San Jose, in September 2023. 

Or, join a live, expert-led webinar to blend the instructor-led experience Lion is known for with the train-anywhere convenience of online learning. Lion instructors will touch on the new proposed regulations, the latest updates, and the must-know provisions for generators in the Golden State, 

Tags: California, generator improvements rule, RCRA

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