There’s already a lot about RCRA that’s new and different, in part thanks to the Generator Improvements Rule finalized in late 2016
. EPA has more new rules planned for late 2018 and early 2019—two of which will simplify things for some hazardous waste generators.
Be confident you know what it takes to keep your facility in compliance with the latest RCRA rules for generators. Before the end of the year, the RCRA Hazardous Waste Management Workshop comes to Houston, Boston, Manchester, Hartford, Northern NJ, and Philadelphia.
Management Standards for Hazardous Waste Pharmaceuticals
This long-promised rule to simplify and improve management of hazardous waste pharmaceuticals for healthcare facilities may soon be a reality.
Proposed in 2015
, the forthcoming Final Rule will add a Subpart P to the hazardous waste management standards in 40 CFR Part 266.
One of the most notable changes in this rulemaking will be to exclude pharmaceutical hazardous waste from counting toward a facility’s generator status.
This could allow some facilities to “move down” to a small quantity or even very small quantity generator, which would further limit the scope of RCRA compliance responsibilities.
This rule could have wide-ranging impacts on pharmacies, vet clinics, physicians’ offices, dentists’ offices, chiropractors, outpatient care centers, other ambulatory healthcare services, hospitals, nursing care facilities, continuing care retirement communities, some medical examiners and coroners’ offices, and various NAICS pharmaceutical reverse distributors.
EPA plans to promulgate a Final Rule by the end of 2018. Stay tuned to Lion News for more on this major rulemaking.
Adding Aerosol Cans to the Universal Waste Regulations
EPA plans to add aerosol cans to the list of wastes that may be managed as universal waste, as proposed in March 2018.
Today, generators and facilities manage aerosol cans under a patchwork of State laws, regulations, policies, and guidance documents. The rule EPA plans to finalize will allow universal waste handlers to “treat” aerosol cans on site using a commercial puncturing or crushing device designed for that purpose.
Generators may manage aerosol cans as universal waste only once their state has adopted an exclusion to match the new Federal one. Because the new rule will make the regulations less stringent, states can decide whether to adopt this new universal waste allowance. Some states (like Ohio) already allow for aerosol cans to be managed as universal waste in some capacity.
Other New RCRA Rules for 2019
EPA also has two proposed hazardous waste management rulemakings in the works for 2019.
Chemical Manufacturers, Power Plants, and Refineries: Financial Responsibility Under CERCLA
EPA may propose a rule to require proof of ability to pay for environmental contamination under CERCLA (Superfund) for facilities in the chemical manufacturing, petroleum, and coal sectors (mostly refineries), as well as the electricity generation industry. EPA plans to propose the rule in Summer 2018 and issue a Final Rule by the end of 2020. (RIN 2050-AH03)
Flash Point Test for Ignitability
The agency plans to update the flash point test methods for the hazardous waste characteristic of ignitability. This RCRA update, slated to be proposed in November 2018,
will allow the use of more modern testing instruments. Currently, the ignitability test methods are based on "outdated" ASTM standard that requires the use of instrumentation that is no longer widely available.
The new ignitability test methods will also remove the requirement to use mercury thermometers in testing. EPA will also solicit comment about the alcohol exclusion for ignitable aqueous alcohols, and whether revisions are necessary to improve hazardous waste management in this area. (RIN 2050-AG93
Expert RCRA Training for Environmental Professionals
US EPA requires personnel at sites that generate hazardous waste to complete training annually [40 CFR Part 262, Subpart A]. Fulfill this EPA requirement and get up to speed on the latest rules for managing hazardous waste at your site. With collaborative, nationwide public workshops; interactive and convenient online courses; and on-site group options, Lion Technology offers effective RCRA training for oil and gas professionals of any experience level or education background.
RCRA Hazardous Waste Training.
US DOT Required Hazmat Shipper Training
All “hazmat employees”—those involved in preparing US DOT-regulated hazardous materials for transport by ground, air, or vessel—must complete training once every three years. [49 CFR 172.704(c)] Explore your options for training oil and gas personnel on the DOT rules for shipping hazmat, including Class 3 flammable liquids and waste shipped on a Manifest.
Hazmat Shipper Training.