In September 2015, the USEPA published proposed, revised rules under the title, “Hazardous Waste Generator Improvements”. Initially, a public comment period ending November 24, 2015 was established, but the comment period has been extended until Dec. 24, 2015. The new rules are meant to clarify and streamline the regulations, but they also include additional labeling and recordkeeping requirements for some.
The new rules are truly a mixed bag for the regulated community. The hazardous waste regulations are notoriously cumbersome, non-intuitive, and often self conflicting, so a revision is sorely needed. Also, the proposed rules include easing of restrictions for companies that have episodic (non-routine) events that, under the current rules, would cause them to be placed in a more stringent generator category (e.g. a small quantity generator must move to large quantity generator status). However, despite these improvements, additional record keeping and more stringent closure requirements will certainly increase the regulatory burden of many generators.
To follow the rule, visit the EPA’s webpage at: Hazardous Waste Generator Improvements Rule
Also, stay tuned to CTI’s blog, twitter feed, and newsletter for more detailed analysis of the implications of these rules.