The option to manage hazardous waste in a satellite accumulation area (SAA) in addition to or instead of a central accumulation area (CAA) is available to both the large quantity generator of hazardous waste (LQG) and small quantity generator of…
Q&A: Are VSQGs required to register under the Generator Improvements Rule?
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…
Mixing Hazardous Waste with Non-Hazardous Waste Under the Generator Improvements Rule
Generators of hazardous waste are required to conduct a hazardous waste determination and to count the hazardous waste generated in order to determine their hazardous waste generator category. If a generator mixes its hazardous waste with a solid waste (i.e.,…
The Hazardous Waste Determination Under the Generator Improvements Rule
A generator of hazardous waste must conduct a hazardous waste determination for all solid waste it generates. This requirement is codified in federal regulations at 40 CFR 262.11. A solid waste is defined and explained at 40 CFR 261.2, but…
Comparison of Changes to the Hazardous Waste Determination Regulations Made by the Generator Improvements Rule
In another article I review in detail the federal USEPA regulations of 40 CFR 262.11 and its requirements to conduct a hazardous waste determination as those regulations were changed by the Generator Improvements Rule. Read: The Hazardous Waste Determination Under…
Marking of a Hazardous Waste Container for Off-Site Transportation
In an earlier article I explained all of the new marking and labeling requirements for all stages of hazardous waste management (central accumulation area, satellite accumulation area, preparation for off-site transportation, 10-day transfer site, and treatment, storage, and disposal facility…
Quick Take: An Example of one of the Changes to USEPA Regulations by the Generator Improvements Rule
The Generator Improvements Rule created ~60 changes to the Federal regulations of the USEPA for the management of hazardous waste. Some of those changes are significant; such as the allowance for Episodic generation of hazardous waste by a VSQG or…
FAQ: Which regulations of the Generator Improvements Rule are more strict than existing USEPA regulations?
The Generator Improvements Rule went into affect at the Federal level and in states lacking an authorized hazardous waste program on May 30, 2017. The new rule contained approximately 60 changes to existing RCRA regulations. Some of the changes were…
Everything About the Generator Improvements Rule
This site will serve as a single location for information related to the Generator Improvements Rule. Articles providing more information are available through the links below. Daniels Training Services, Inc. 815.821.1550 Info@DanielsTraining.com https://www.danielstraining.com/ General Information and Background: Summary of Proposed…
FAQ: What is the AHJ?
AHJ is an acronym used by USEPA for the authority having jurisdiction (AHJ) over the fire code of a particular area. Adopted by the USEPA for use in the Generator Improvements Rule’s revision to the 50 Foot Rule, it was…