Hazardous Waste Generator Improvement Rules

Hazardous Waste Generator Improvement Rule Forms

On 30 May 2017, EPA finalized the biggest change to the hazardous waste management regulations since the landfill restrictions 30 years ago. The Hazardous Waste Generator Improvement Rule (HWGIR) completely reorganizes section 262 of 40 CFR and combines it with the CESQG rules in 261.5.

We took a hard look at the new rules and decided, as a service to the regulated community, to create a set of documents to help hazardous waste generators understand and incorporate the HWGIR into their operations. Those documents and forms are described and presented in the “Downloadable Forms” section to the right.

Yes, you will be asked to give us your contact information. Don’t be afraid. We are not the inbox-saturating types. But we will be occasionally letting you know about regulatory changes, industry updates, and some case studies from current news about how others have gotten into hot water for failure to know the rules.

NOTE: The federal rules are final, but States that have their own EPA programs will have to adopt the new HWGIR as part of State law. This may take up to a year, but keep an eye open for their publication because the States can add their own requirements to the HWGIR.

Downloadable Forms

This document is a line-by-line simplification of the entire HWGIR. Every single section of the rule is covered here except for the sections relating to Farmers, Import/Exports, and Academic Entities. We have put the HWGIR Summary in a table form for clarity and we have included many links to the actual text of the Code of Federal Regulations at 40 CFR.

Here is the link to the document:
New Rule Summary

This document is an extremely condensed, side-by-side comparison of the new “Conditions for Exemption” for Large Quantity Generators (LQG’s), Small Quantity Generators (SQG’s), and Very Small Quantity Generators (VSQG’s, formerly known as CESQG’s). Numerous links go back to the actual text of 40 CFR.

Here is the link to the document:

Here are the instructions for completing the Hazardous Waste Determination Form, item 3b on this list. This document is for those who are not very familiar with the procedure for determining if a waste is “RCRA Hazardous” and for proper application of the EPA Hazardous Waste Codes.

Here is the link to the document:

The new HWGIR requires SQG’s and LQG’s to maintain records of the Hazardous Waste Determinations conducted on their wastes. This fillable form is designed to provide all the information required by the greatly expanded regulation at 40 CFR 262.11. VSQG’s are not required to keep these records, but it would be a good idea to get into practice just in case you graduate to a larger category of waste generator. It would also make a very good impression on any regulators that come by to inspect your waste management system. Download and save a blank form as a template. Fill and re-save for each waste.

Here is the link to the document:

The best thing about the new HWGIR is allowing generators to have an exemption for unusual waste-generating events. This allows a SQG to remain SQG even if they have a spill or other event that puts them over the standard limit of 2200 lbs per month. The only catch: To get the exemption, you MUST notify the State or Federal EPA. The HWGIR does not specify a form to use, so we made one.

The link below is only for SQG’s and is found here:

We’re really glad that EPA didn’t leave all you VSQG’s out in the cold regarding the Episodic Waste Exemptions. Now, you can remain VSQG (a big advantage) even if you have a single event that would put you over the 220 lb per month limit. But don’t forget: To get the exemption, you MUST notify the State or Federal EPA. Otherwise, they can cite you for being an SQG without an ID# and for ignoring all the SQG requirements. That would hurt.

Here is the form that we have created for VSQG notification of episodic waste-generating events: