In 2016, EPA adopted the Hazardous Waste Generator Improvements Rule that includes a requirement for all small quantity generators (SQGs) to re-notify the EPA or state agency of hazardous waste activities. In short, SQGs generate more than 100 kilograms but less than 1,000 kilograms of non-acute hazardous waste per month. SQGs must re-notify EPA or their state agency by September 1, 2021 and every four (4) years thereafter.
To determine applicability and submit the re-notification you should:
- Determine if your facility location(s) is under EPA jurisdiction or if your state has adopted and been authorized for the Hazardous Waste Generator Improvements Rule
- Verify your hazardous waste generator status and reporting requirement using the applicable regulations
- Some authorized states have definitions of hazardous waste generator categories that are more stringent than EPA’s definitions and/or may require reporting more frequently and/or in addition to the SQG re-notification
- Determine if a complete notification was submitted for your facility during the four (4) years prior to the due date
- If you submitted a complete notification of regulated activity or EPA Site ID Form (or state equivalent) anytime within the four years before the September 1, 2021 deadline the re-notification obligation is considered to be met
- The requirement for generators to re-notify whenever there is a change to the site contact, ownership, or type of RCRA Subtitle C hazardous waste activity conducted remains in place and is independent of the four (4)-year re-notification requirement
- Identify the required method to be used when filing the SQG re-notification
- EPA generally requires Notification of RCRA Subtitle C Activities (Site Identification Form), also known as EPA Form 8700-12, and many states have adopted the use of this form
- Consult form instructions for correct mailing address if sending hard copy form
- Some states allow (or require) use of an electronic system, such as MyRCRAID
- Signatory/certification requirements (e.g., Responsible Corporate Official) should be determined and form/submittal must be signed/certified accordingly
VBA professionals can assist you with identifying and fulfilling environmental compliance obligations. Please contact a VBA Compliance Assurance professional if you need assistance with hazardous waste generator reporting and/or EHS compliance.