A question from a former customer on February 14, 2018:
Hello Daniel,
I attended one of your training sessions several years ago and enjoy your newsletters.
My question is regarding VSQG changes. I’m pretty sure all of our sites probably fit into this category as we rarely deal with hazardous waste. Usually it’s either lab or process chemicals that are no longer needed.
So, I guess I have a couple questions:
- I’ve heard that VSQGs will be required to register but Arizona still has not adopted the EPA’s Generator Improvements Rule so our state agency (Arizona Department of Environmental Quality or ADEQ) is being very closed mouthed at this time. At the time of this writing ADEQ had not yet adopted the Generator Improvements Rule. It did on February 5, 2019. Read about the status of the Generator Improvements Rule in your state.
- If we contract a hazardous waste hauler, are we the generator or are they? I’m assuming it would be us because of the cradle to grave thing.
Keep up the good work!
Thank you,
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Not sure of your hazardous waste generator status? |
Such positive feedback! I had to reply that day:
Thank you for contacting me. Please see below.
- There is no requirement in the new Generator Improvements Rule for VSQGs to register. There is a new requirement for SQGs to re-notify every 4 years beginning in 2021 and for LQGs to re-notify every two years. I am not aware of any requirement in the Arizona regs for such a requirement.
- A VSQG may be required to register under the new rule if it consolidates its waste at an LQG or if it has an episodic hazardous waste generation event.
- The generator of a hazardous waste is the person by site or act who generates the hazardous waste. That would be you. The hauler is the hazardous waste transporter. You are correct that you have a cradle-to-grave responsibility for the hazardous waste you generate.
I hope this helps.
Please contact me with any other questions.
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Daniels Training Services, Inc. 815.821.1550 |