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. Some states previously required annual waste reporting for SQGs, in which case they are already submitting a re-notification.
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 the environmental compliance team at NGE.
Contact Us Now
The United States Environmental Protection Agency (EPA) published the ﬁnalized amendments to the General Provisions that apply to the National Emission Standards for Hazardous Air Pollutants (NESHAPs) under section 112 of the Clean Air Act (CAA) in the Federal Registrar on October 1, 2020.
These amendments allow a source to reclassify to an “area source” (non-major) of Hazardous Air Pollutants (HAP)s at any time upon reducing its Potential to Emit (PTE) below 10 tons per year (tpy) of a single HAP or 25 tpy of all HAPs combined.
In 2019, the EPA added hazardous waste aerosol cans to the federal universal waste list, which allows generators to manage the cans with the less burdensome universal waste requirements. The final rule became effective on February 7, 2020, and applies to those who generate, transport, treat, recycle or dispose of hazardous waste aerosol cans. Under the universal waste rule, generators and handlers can store cans for a year and manage all aerosols together provided they are punctured and drained of any free liquid. (Note that the collected liquid from draining the aerosol cans will likely be considered hazardous waste.)
Per- and polyfluoroalkyl substances (PFAS) are a group of man-made chemicals that have been the subject of new regulations in recent years. Beginning with the 2020 reporting year, 172 new PFAS chemicals have been added to the list of reportable chemicals under Toxic Release Inventory (TRI) program. Facilities that manufacture, process, or use 100 pounds or more per year of any of the listed PFAS chemicals must include those chemicals in their annual TRI report due July 1, 2021.