The Hazardous Waste Generator Improvements Rule (Rule), finalized on November 28, 2016, will require hazardous waste large quantity generators (LQGs) and small quantity generators (SQGs) to make many changes as to how they manage their hazardous waste.

Pretransport Marking – The Rule requires generators to mark the applicable U.S. Environmental Protection Agency (EPA) hazardous waste numbers (i.e., EPA hazardous waste codes) on each container before transporting them off-site.

Satellite Accumulation Area Containers Marking – A container holding hazardous waste in a satellite accumulation area must be marked with the words “Hazardous Waste,” and an indication of the hazards of the contents (e.g. DOT labels or placards, an OSHA hazard statement or pictogram, or an NFPA 704 diamond).

VSQGs – Under the new rule, industrial entities previously called conditionally exempt small quantity generators (CESQCs), are now termed very small quantity generators (VSQGs). This change reflects the actual regulatory language since the other two generator categories—small quantity generators (SQGs) and large quantity generators (LQGs)—are also conditionally exempt from some requirements. VSQGs are potentially affected by only two of the new provisions: (1) VSQGs may send hazardous waste to LQGs under the control of the same person; and (2) QGs may also maintain their existing regulatory status if they have an episodic event that generates additional amounts of hazardous waste that would have resulted in them moving into a higher generator category for a short period of time.

Miscellaneous Other Provisions – Other revisions and new provisions in the rule affect disposal of liquid hazardous waste in a landfill, clarify generator waste counting, clarification of what is acceptable knowledge for hazardous waste determinations, requirement that SQCs notify EPA every 4 years of generator status, and the LQCs attempt to make arrangements with the local police department, fire department, and other emergency response teams; emergency response contractors; equipment suppliers; and local hospitals.

The federal Hazardous Waste Generator Improvements Rule becomes effective May 30, 2017.