The United States Environmental Protection Agency (USEPA) Hazardous Waste Generator Improvements Rule included a new notification requirement that will take effect in 2021 for small quantity generators (SQG) of hazardous waste. Be sure that you understand this new SQG Notification Requirement and how these changed will affect your state.
On September 1, 2021, the USEPA will require SQGs to submit a re-notification of their generator status.
Previously, SQGs only needed to provide their initial notification using form 8700-12 (RCRA Subtitle C Site Identification Form) to obtain an EPA ID number. No further information regarding SQG waste activities had was unless specified by their state.
In states where SQGs are required to submit annual waste reports, this re-notification would not apply. Additionally, if Form 8700-12 has been submitted within the four years prior to this deadline, this would meet the notification requirement. Moving forward, this re-notification will need to be completed at least once every four years.
Visit the USEPA’s website for an up-to-date, interactive map of states that have authorized the Hazardous Waste Generator Improvements Rule, as well as states where it was adopted.
2021 SQG Notification Requirement
Under the Improvements Rule, SQGs must re-notify every four (4) years. You can complete this notification using the updated form 8700-12 or the USEPA online tool called myRCRAid.
Note that if you submit form 8700-12 anytime during the four years before the deadline, the USEPA considers this sufficient to meet SQG notification requirements.
If you are an SQG or need assistance with your hazardous waste notifications contact us.