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2017 RCRA ChangesLast month we talked a bit about the importance of getting an On-Site Review every two years and we were excited to have some of you get a repeat review scheduled with us!  Along those same lines, this month we’re focusing on a specific regulation that saw some changes earlier this year – the U.S. Environmental Protection Agency's Resource Conservation and Recovery Act (RCRA).

RCRA dictates hazardous and non-hazardous solid waste management and the changes made this year were the first ones in over 30 years made to a portion of the regulation known as the Hazardous Waste Generator Improvements Rule.

Over 60 changes aimed to reorganize the rule to make it easier to understand and address ambiguities are included in the rule change.  Additionally, the updates provide greater flexibility for hazardous waste generators to manage waste in a cost-effective manner through episodic generation and Very Small Quantity Generators of Hazardous Waste (formerly Conditionally-Exempt Small Quantity Generators (CESQG)) – Large Quantity Generators (VSQG-LQG) consolidation provisions.

For IWRC clients, here are the primary updates that could affect your business:

  • Confirmation regarding when generator’s hazardous waste determination must be made
  • Information on how to determine if a solid waste is either a listed and/or characteristic hazardous waste
  • Identifies what waste determination records must be kept
  • Additional flexibility for VSQG and SQG in regards to planned and unplanned episodic waste generation events
  • Adding marking and labeling requirements for storage containers prior to sending hazardous waste off-site

Regulatory information for Very Small Quantity Generators (VSQG) and Small Quantity Generators (SQG) have been updated on our website; simply click on your category on the Hazardous Waste page. Iowa small businesses with less than 200 employees can get free and confidential direct assistance from our environmental specialists who will help to make sure you understand what needs to be done to comply with the new Hazardous Waste Generator Improvements Rule and they can cover any other compliance concerns or questions about other applicable environmental regulations while we’re there.  To get your On-Site Review scheduled, complete the form on our Contact Us page or give us a call at 319-273-8905.

We look forward to working with you and keeping you compliant with RCRA.

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