On Monday, August 31, 2015, EPA released a pre-publication
version of a proposed rule revising RCRA's hazardous waste
generator regulations. EPA's stated goals for the proposal are
to improve compliance, address regulatory gaps, give hazardous
waste generators greater flexibility, and make the regulations more
user-friendly. This summary highlights some of the changes proposed
by EPA.
First, the proposed rule would allow a small quantity generator
(SQG) and a newly-defined "very small quantity generator"
(VSQG)—which replaces the term "conditionally exempt
small quantity generator" (CESQG)—to maintain its
generator category if either a planned or unplanned episodic event
occurs which would ordinarily bump the generator to a more
stringent category. This change would allow VSQGs and SQGs to
maintain their existing generator categories despite the additional
generation, so long as they comply with certain conditions.
