Current hazardous waste rules are changing and could have an affect your industry. The hazardous waste e-manifest system is on track for a 2018 rollout, and many other changes are in store that could change the requirements of businesses nationwide. SESCO Group specializes in helping businesses cut through the red-tape and reach their objectives safely and without the risk associated with non-compliance.
Count on SESCO as You Navigate the Changing Hazardous Waste Rules.
Filing of Forms Online:
- If your facility is currently filling out EPA Forms 8700-22 and 8700-22A, you will, under the new hazardous waste rules, be required to fill these forms out online.
- Some chemical manufacturing companies with security concerns are exempt from the online filing requirement.
Revised Definition of Solid Waste Rule:
In a continued effort to clarify the definition of what constitutes solid waste, the EPA has attempted to change what constitutes a solid waste. This complicated and somewhat controversial rule has been challenged in the courts.
Here’s what the rule states: the “definition of solid waste” (DSW) rule states that hazardous waste generators only need to make “reasonable efforts” to ensure a recycler is reclaiming rather than disposing of recyclable hazardous secondary materials. In July 2017, the D.C. Circuit Court of Appeals overturned one of the legitimacy factors of the DSW rule called the “verified recycler exclusion” (VRE). While this decision leaves reason for industry to breathe a sigh of relief, generators and recyclers of hazardous secondary materials need to carefully consider the EPA’s new ruling in total to ensure that they are adhering to the new requirements.
The Hazardous Waste Generator Improvements Rule (HWGI):
The EPA recently rolled out the hazardous waste generator improvements (HWGI) rule and the rule is set to be adopted and implemented at the state level affecting upwards of 700,000 or more industrial sources. Compliance procedures will vary by states, and it’s vital that industries understand how the unique state changes will affect their operations.
How states are stacking up: State agencies are working under a July 1, 2018, deadline to update their Resource Conservation and Recovery Act (RCRA) programs to make them conform to the new HWGI rule.
- So far, only four states, (PA, GA, UT and NJ) have adopted the rule.
- Two states and two territories (IA, AK, PR and VI) are regulated for RCRA on the federal level (by EPA), so they are already subject to the HWGI rule.
- This means only eight states and territories are currently following the new HGWI.
Navigating these hazardous waste rules can get complicated as states have a few options. They may choose from many relaxed standards in the HGWI, but no state rules can be less stringent than the federal standards. Different states may choose different relaxed standards to adopt.
The SESCO Group specializes in helping businesses in IN, OH, KY and TX and can provide expertise in understanding which provisions of the HWGI may affect your state and your industry.
Founded in 1996, SESCO specializes in providing environmental consulting and redevelopment services across Indiana and surrounding areas. Partner with us for characterization and remediation of environmentally impacted properties, complicated property transactions, Brownfield and commercial redevelopment, and environmental liability protection.