Tom Barnes
Compliance Specialists, Inc.

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. Before making any changes, please see if your state has adopted these new rules. If not, find out if they intend to in the near future as most states are in the process of adopting the new rules.

A summary of the changes created by this new rule is as follows:

• Realignment of the Regulations: The new regulations have placed most, if not all, of the generator requirements in one section.
• CESQG vs. VSQG: If you have inthe past been considered a Conditionally Exempt Small Quantity Generator (CESQG), you will now be referred to as a Very Small Quantity Generator (VSQG) and will have some additional regulations with which to comply.
• Conditions for Exemptions: In order to qualify for exemptions from the massive Treatment Storage Disposal Facility (TSDF) regulations as a very small, small, or large quantity generator, you will have to comply with certain regulations. Failure to meet these conditions for exemption will subject your facility to the full TSDF regulations.
• Episodic Events: This is a great benefit to VSQGs and Small Quantity Generators (SQG). As long as you follow the requirements set forth in the regulations, you can now exceed your monthly limits for generation of hazardous waste once per year without being pushed into the higher generator category.This will allow you to ship off old varnish from a tank as a hazardous waste without having to worry about generator status. Be sure to review the rules for both planned and unplanned episodic events.
• Waste Labeling: Now, in addition to labeling your hazardous waste with just the words “hazardous waste,” you must label with an “indication of hazards.” The EPA allows this to be accomplished with U.S. Department of Transportation (DOT) hazard labels or placards, Globally Harmonized System (GHS) labeling, or National Fire Protection Association (NFPA 704) labeling.
• Solvent Wipe Rule:  This rule allows exemption for laundered rags and some relief from the regulations for disposable rags. Google “Solvent Wipe Rule” for more information.

EASA’s Management Services Committee hopes you find this information useful. We will continue to provide environmental updates as they become available.