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

Find a Post

Compliance Archives

Lion - Quotes

I was able to present my scenario to the instructor and worked thru the regulations together. In the past, I attended another training firm's classes. Now, I have no intention of leaving Lion!

Diana Joyner

Senior Environmental Engineer

The instructor was very patient and engaging - willing to answer and help explain subject matter.

Misty Filipp

Material Control Superintendent

The instructor was very knowledgeable and provided pertinent information above and beyond the questions that were asked.

Johnny Barton

Logistics Coordinator

If I need thorough training or updating, I always use Lion. Lion is always the best in both instruction and materials.

Bryce Parker

EHS Manager

I can take what I learned in this workshop and apply it to everyday work and relate it to my activities.

Shane Hersh

Materials Handler

Lion's online training is more comprehensive, has better slides, and is a superior training experience than what I would get from other trainers.

Robert Brenner

District Environmental Manager

This training broke down the regulations in an easy-to-understand manner and made them less overwhelming. I now feel I have the knowledge to make more informed decisions.

Amanda Oswald

Shipping Professional

I had a positive experience utilizing this educational program. It was very informative, convenient, and rewarding from a career perspective.

John Gratacos

Logistics Manager

Best course instructor I've ever had. Funny, relatable, engaging; made it interesting and challenged us as the professionals we are.

Amanda Schwartz

Environmental Coordinator

The instructor was excellent. They knew all of the material without having to read from a notepad or computer.

Gary Hartzell

Warehouse Supervisor

Download Our Latest Whitepaper

What to do before, during, and after a RCRA hazardous waste inspection to defend your site from rising State and Federal penalties.

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.