EPA Proposes Major RCRA Overhaul

Posted on 9/1/2015 by Roger Marks

On August 31, 2015, US EPA proposed a complete overhaul of the Resource Conservation and Recovery Act (RCRA) regulations for managing hazardous waste.

Called the “Hazardous Waste Generator Improvements Rule,” the proposal lays out a re-structuring of the RCRA rules within the generator management standards at 40 CFR Part 262, defines certain key terms, and adds some new requirements.

Lion Members—get a full breakdown of changes in the Member Bulletin sent by email today, and now available here.

Goodbye CESQG!

EPA’s proposal will replace the term “conditionally exempt small quantity generator” with a new name, “Very small quantity generator.”

This change was inspired by the fact that following the rules at 40 CFR 262 grants ALL generators a conditional exemption from the more stringent hazardous waste management standards for permitted storage facilities in Part 265, et al.

Managing hazardous waste under changing RCRA regulations

Moving the RCRA Rules Around

The changes EPA proposed include a major re-structuring of the RCRA rules. In brief, the generator rules at 40 CFR Part 262 commonly refer personnel to other parts of 40 CFR, like part 261, Part 268, and others. Many of these rules will be copied and/or transferred to Part 262 to make navigating the RCRA regulations easier.

New RCRA Rules Added

In addition to restructuring and re-wording changes, EPA has added some new management standards for hazardous waste, like:
  • New marking requirements for hazardous waste containers
  • Requiring ANNUAL re-notifications for LQGs and SQGs under 49 CFR 262.18
  • Requiring LQGs and SQGs to create and maintain records to support solid and hazardous waste determinations
New Standards for Episodic Waste Generation

EPA’s proposal provides new standards for “episodic generation”—a common situation faced by generators where more than the usual amount of hazardous waste is generated in a given month. The new standards provide options for generators to manage this extra waste without a change to generator status [i.e. Large Quantity, Small Quantity (CESQG)].

Lion Members—Get a Full Breakdown

Lion Members can log in to get a full breakdown of the new rules here. To become a Lion Member, attend the Hazardous/Toxic Waste Management Workshop or sign up for the new RCRA refresher online course!

For more information about Lion Membership, visit

Tags: EPA, hazardous waste, new rules, RCRA

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