New Changes to Requirements for Hazardous Waste Generators now in Effect

We previously did a series of blogs (www.altiras.com/blog) to explain the upcoming changes to RCRA regulations that will impact generators of hazardous wastes.  The changes went into effect on May 30, 2017.  The eight areas of change are:

1. Reorganization of the Hazardous Waste Generator Regulations and modifies the organization of the Preamble.
2. Changes to 40 CFR Part 260, which covers definitions
3. Changes to 40 CFR Part 261, requiring biennial reporting by facilities that recycle hazardous waste without storing it.
4. Changes to 40 CFR Part 262, which covers the standards applicable to generators of hazardous waste
5. Additional changes to 40 CFR Part 262 for generators that would ordinarily have changed status due to an episodic event
6. Additional changes to 40 CFR Part 262 clarifying expectations related to Preparedness, Prevention, and Emergency Procedures for SQG’s and LQG’s
7. Technical corrections and changes to 40 CFR Part 257
8. New discussion of “Electronic Tools to Streamline Hazardous Waste Reporting and Record keeping Requirements”

If you missed our prior blogs, you can look for them in our archives.  For more information about these changes, please contact Todd Pencarinha at 713-568-3651 or at info@altiras.com

Effective Waste Management

Todd Pencarinha is the president of the Houston, Texas-based industrial reuse firm Altiras. A chemical engineering graduate with distinction of the Ohio State University, Todd Pencarinha has led Altiras to establish industry best practices in quality assurance and product stewardship involving the beneficial use of materials that would otherwise be considered solid wastes.

    According to the Resource Conservation and Recovery Act (RCRA), unless specifically excluded by the regulations, a solid waste is defined as any discarded material that is abandoned, recycled, considered inherently waste-like, or military munitions. However, the RCRA definitions are very specific and often do not match the Webster’s dictionary definitions. For example, the definition of “abandoned” includes disposal, burning or incineration, or even accumulating, storing or treating these materials.

    Similarly, “solid wastes” are not always solid, but are described as such since RCRA has separate regulations for air and water pollution. The RCRA definition includes liquids, semi-solids, and contained gasses. Examples of solid waste include everyday garbage, as well as industry-specific materials such as sludge from a wastewater treatment plant, waste chemicals, and used solvents.

    The RCRA definition of “recycling” can also be confusing since it includes direct reuse, although direct reuse can allow for exclusion from solid waste regulation.

    Are you confused yet? If you are, then you are among good company. The RCRA regulations are not easy to interpret and can take years to master. Once mastered, don’t worry, they will be changed again.