In late 2016, the U.S. Environmental Protection Agency (EPA) issued a new rule called the “Hazardous Waste Generator Improvements Rule.” In the U.S. over the past 18 months, many states that members do business in have adopted new rules which now affect the management of hazardous waste. Some are beneficial and some could create additional legal exposure to your business.

As we enter a new and exciting year of operating EASA businesses, we must remember that almost all service centers in the U.S. with either dip or vacuum pressure impregnation (VPI) tanks will be subject to the SARA Title 3, Tier II, reporting requirements. This requirement is part of the Emergency Planning and Community Right to Know Act (EPCRA). The EPCRA involves notifying the state and local community of any hazardous chemical stored onsite in quantities over 10,000 lbs. A hazard material for the purpose of this regulation is anything hazardous under the Hazard Communication standard. In other words, if it has a Safety Data Sheet and you had more than 10,000 lbs onsite at any time during the previous year (2017), then you are subject to this reporting requirement.  For most EASA centers, this will include the VPI, the dip tank varnish, or, in some cases, both varnishes.