New EPA Rule Reduces RCRA Reporting Requirements

On April 4, 2006, EPA published a new rule regarding federal hazardous waste regulations in an effort to reduce recordkeeping, reporting, and inspection requirements imposed on businesses, states, and the public. See 71 Fed. Reg. 16862 (Apr. 4, 2006). The new rule, which becomes effective May 4, 2006, is intended to reduce the paperwork burden imposed under the Resource Conservation and Recovery Act (RCRA). Industries affected by the new rule include manufacturing, transportation, waste treatment, utilities and mineral processing operations.

Although billed as a paperwork reduction measure, the new regulations will significantly alter the way many affected businesses conduct their operations. It also will make compliance with many RCRA requirements less onerous. In our experience of counseling and defending businesses on RCRA compliance matters, recordkeeping, reporting and inspection requirements that may seem very simple often lead to significant non-compliance issues when not