The EPA recently issued an update to the hazardous waste generator regulations under Resource Conservation and Recovery Act (RCRA). This update provides greater flexibility in how hazardous waste is managed and closes gaps in its regulation. Improvements include provisions for episodic generation, name change (and options) from CESQG to VSQG, and other changes.
Understanding Regulatory Changes
Keeping up to date with these changes is an important part of environmental compliance. Consider the following real-life example:
Recently, Braun Intertec was contacted by a local business requesting help with waste compliance issues documented during an unannounced regulatory inspection. The inspector noted multiple alleged violations related to improper hazardous waste management and incomplete waste disposal record keeping. Upon review, Braun Intertec discovered that the facility had been improperly coding their waste and was erroneously documenting universal wastes as hazardous wastes. The business was under the assumption that their facility was a small quantity generator (SQG) when they were actually a conditionally exempt small quantity generator (CESQG, soon to be VSQG). Braun Intertec assisted them with reclassifying their waste streams and correcting past manifests. Once the corrections were made, the business was able to reclassify their generator status as a CESQG, relieving themselves of the additional SQG regulatory requirements and avoiding the prior alleged violations. A better understanding of the hazardous waste regulations and how they apply to your facility will help your company save money by preventing costly violations and increased regulatory scrutiny.
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