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Two Major RCRA Hazardous Waste Proposals in Today’s Federal Register

Posted on 9/25/2015 by Roger Marks

Update: US EPA has announced two public webinars to discuss these major RCRA rule changes. The Hazardous Waste Pharmaceuticals Proposed Rule webinar will be held on Tuesday, October 13 at 2 PM EDT.  The Hazardous Waste Generator Improvements Proposed Rule webinar will be held on October 15 at 2 PM EDT. 

In the September 25, 2015 Federal Register, US EPA posted two proposed rules that will affect hazardous waste generators, the Hazardous Waste Generators Improvements Rule and the Management Standards for Hazardous Waste Pharmaceuticals Rule. 

Hazardous Waste Generators Improvements Rule

The first is EPA’s Hazardous Waste Generator Improvements Rule, aimed at consolidating the RCRA hazardous waste regulations, which are currently spread across Title 40 of the Code of Federal Regulations, into Part 262. Read the proposed rule in the Federal Register.  
In addition to restructuring changes, EPA has added some new management standards for hazardous waste, such as:

  • New marking requirements for hazardous waste containers;
  • Requiring ANNUAL re-notifications for LQGs and SQGs under 40 CFR 262.18;
  • Requiring LQGs and SQGs to create and maintain records to support solid and hazardous waste determinations;
  • EPA’s first official standards for “episodic” waste generation—the term for a facility generating more than its usual monthly volume of hazardous waste in a given month.
Read more about the Hazardous Waste Generators Improvements Rule.

RCRA hazardous waste drum label
Management Standards for Hazardous Waste Pharmaceuticals

The second major RCRA rules in today’s Federal Register affects hazardous waste generators in the healthcare sector. This rule aims to help retail pharmacies, vet clinics, doctors’ offices, dentists’ offices, chiropractors, outpatient care centers, hospitals, and more to manage and dispose of hazardous waste pharmaceuticals. 

In addition to officially prohibiting drain disposal of pharmaceuticals, the proposed rule will add a new Subpart P to 40 CFR 266 to house new management standards for this special type of hazardous waste. The proposed rule can be found in the Federal Register here.  

Highlights of the proposed rule include:

  • Requiring a one-time Notification for non-CESQG generators of pharmaceutical hazardous waste;
  • Creating a new RCRA Facility Category, Pharmaceutical Reverse Distributors;
  • Excluding pharmaceuticals managed under the new Subpart P from counting toward a facility’s hazardous waste generator status; and
  • Setting training requirements for personnel at healthcare facilities. 

Read more below:

Hazardous Waste Pharmaceutical Management Standards in New RCRA Subpart P
Management Standards for Hazardous Waste Pharmaceuticals

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Tags: EPA, hazardous waste, new rules, RCRA

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