Last fall, the U.S. Environmental Protection Agency (EPA) issued a proposed rule that will dramatically impact businesses that generate hazardous waste. Published Sept. 25, 2015 (80 Fed. Reg. 57918), the “Hazardous Waste Generator Improvements Rule” is the first comprehensive overhaul of the federal framework governing hazardous waste management by generators since the program was promulgated in the 1980s under the Resource Conservation and Recovery Act (RCRA).
While some of the proposed changes should improve a complex program, other aspects will make compliance more burdensome and costly, and in some cases may not justify the accompanying environmental benefits. This article briefly highlights some of the more significant proposed changes, and suggests potential implications for generators based on comments submitted to the EPA during the rulemaking process.
Making, Documenting Hazardous Waste Determinations
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