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Little Waste and No Time

Little Waste and No Time

There is a new reporting deadline quickly approaching for small quantity generators (SQGs) of hazardous waste. Are you prepared?

In the past, SQGs never had to file any Resource Conservation and Recovery Act- (RCRA-) mandated reports, but when the 2016 Hazardous Waste Generator Improvements Rule went into effect, the US EPA introduced a renotification requirement for SQG facilities.

The rule requires all SQGs of hazardous waste to renotify US EPA of their hazardous waste activities every 4 years. The reason for the renotification requirement is to maintain more consistent and accurate data for outreach, compliance support, waste activities oversight, and universally improve SQG information and data. The rule is currently in effect in most states with various adoption dates.

The first renotification submission is due September 1, 2021, for those states that immediately adopted the improvement update, and must be submitted on US EPA Form 8700-12 (Site Identification Form) – the same form originally filed by all generators to notify the US EPA of a generator’s hazardous waste activities. SQGs who file on September 1, 2021, will then be required to renotify on September 1, 2025, unless your state has more frequent reporting schedule.

 Additional SQG reports

Facilities that do not have a RCRA Part B storage permit (i.e., facilities who recycle hazardous waste without first storing the waste) must file a Biennial Report along with large quantity generator (LQG) facilities. The

Biennial Report is due on March 1, 2022, so facilities applicable to this requirement will need to submit a report for the 2021 calendar year.

Additionally, if an SQG or very small quantity generator (VSQG) generates hazardous waste from an episodic event, then the Hazardous Waste Generator Improvements Rule requires that facility to submit at least one of the four forms that make up the Biennial Report. An episodic event occurs when a planned or unplanned event generates a quantity of hazardous waste in a calendar month sufficient to cause the facility to move into a more stringent generator category (i.e., VSQG to either an SQG or an LQG; or an SQG to an LQG).

The deadline for renotification is fast approaching for SQGs. If you need assistance with understanding your generator status, submitting reports, or with any hazardous waste requirements, please contact Cody Dye or Shaun Gilday.

Cody Dye, CSP

EHS Consultant

Shaun Gilday

Senior Advisor/Principal