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EPA Proposed Regulatory Clarifications for Hazardous Waste Generators January 18th, 2016 | Categories: Regulation

As a reminder to NASF members who have inquired about pending changes to federal hazardous waste rules, EPA recently issued a proposed regulation on hazardous waste generator improvements. The proposed revisions are mostly clarifications of the existing requirements for generators, such as how wastes should be labeled and the need to follow closure requirements for hazardous waste tanks, containers, central accumulation areas, or containment buildings that are no longer used at a facility. The proposal also includes some changes in nomenclature (e.g., conditionally exempt small quantity generators, CESQGs, are renamed as very small quantity generators, VSQGs) without any substantive changes to the requirements for hazardous waste generators.

A few proposed changes are new requirements, including provisions to:

  1. document hazardous waste determinations with test results, test methods, QA/QC and basis for determination;
  2. maintain records until a generator closes rather than for only three years;
  3. and submit generator re-notification every two years.

The comment deadline was recently extended until December 24, 2015. Based on a review of EPA’s proposal and input from the surface finishing industry regarding the potential impact of the proposed clarifications, NASF did not submit comments on the proposed clarifications.

If you have any questions or would like additional information regarding the proposed clarifications to hazardous waste generator requirements and the potential impact to surface finishing operations, please contact Jeff Hannapel with NASF at