The Biennial Hazardous Waste Report (due March 1st of every even numbered year for the previous calendar year) is a requirement of the US Environmental Protection Agency for the following:

• Treatment, Storage, and Disposal Facilities (TSDF’s) of hazardous waste.
• Large Quantity Generators (LQG’s) of hazardous waste.
• Small Quantity Generators (SQG’s) of hazardous waste who receive a notice to submit the Report.

However, States with an Approved Hazardous Waste Program may require the Report to be submitted annually (March 1st of every year for the previous calendar year).

Read about the 2011 Hazardous Waste Report due March 1st of 2012.

Until recently Ohio was a state with an approved hazardous waste program that required the Hazardous Waste Report to be submitted annually.  That changed with Ohio Senate Bill 294 which was signed into law by Governor John Kasich in early June and became effective September 5, 2012.  The Ohio EPA does a good job of summarizing how this will impact regulated industry within the state, so I’ll quote the website.

Generator and Facility Report Frequency will change from Annual to Biennial

Senate Bill 294 was signed by the Governor in early June, and becomes effective September 5, 2012.  One component of that bill allows the Director of Ohio EPA to report certain hazardous waste management data to the Governor biennially now instead of annually.  Ohio EPA intends to change certain annual reporting requirements to biennial reporting requirements to correspond with the federal program. 

Under these intended rule changes, your “Hazardous Waste Annual Report” currently due March 1, 2013, for 2012 data would not be required to be submitted to Ohio EPA.  Your first biennial report would be due March 1, 2014, for 2013 data. 

However, if you normally submit other reports/data with your annual report that are not part of that report (e.g., the ground water monitoring annual report required by OAC 3745-65-94), those other reports/data will maintain their annual reporting requirement.

It is our goal to have annual to biennial rule amendments effective prior to March 1, 2013. If the process is delayed for some reason, Ohio EPA will use enforcement discretion and you will not be held to the annual report requirement that is changing to biennial.

So there you have it, right from the Ohio EPA website.  While this will reduce the reporting requirement for hazardous waste generators in Ohio, it doesn’t affect any other rules applicable to generators of hazardous waste, such as the requirement for Large Quantity Generators of hazardous waste to provide annual training for Facility Personnel who may come into contact with hazardous waste or respond to a hazardous waste emergency.  The requirement for training can be found at 3745-65-16 of the Ohio Administrative Code referenced from 3745-52-34(A)(4).

Whether you are located in Ohio or anywhere else in the Union, the hazardous waste regulations of both State and Federal agencies are constantly changing and require you to keep abreast of those changes.  Contact me with questions about the hazardous waste regulations in your state or arrange to attend one of my training sessions.