Published in April 2019 by John D. Cain and Cherie N. McKenna of Novesis, the paper contrasts the pre Hazardous Waste Generator Improvements Rule (HWGIR) version of §262.11 with the revised rule that took effect federally in 2017 (and was expected in South Carolina by mid-2019).
The new language requires generators to make an accurate determination at the point of generation (before any dilution, mixing, or alteration) and whenever waste properties may change; to use and thoroughly document generator knowledge or testing for both listings and characteristics; to identify all applicable EPA waste codes before off-site shipment; and (for small- and large-quantity generators) to retain supporting records for at least three years.
Although EPA described the changes as a clarification of existing guidance rather than a more stringent standard, the paper emphasizes that elevating these concepts into regulation creates a much stronger basis for compliance and enforcement.
It notes that reliance on a Safety Data Sheet alone is no longer adequate, because SDS concentration data are typically reported in percent while RCRA characteristic thresholds are measured in parts per million.
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