The paper explains that the HWGIR (finalized November 2016 and federally effective May 2017) reorganized longstanding SAA provisions and added seven substantive updates.
Generators must now follow the incompatible-waste rules of §265.17(b); keep containers closed except when adding or removing waste or when temporary venting is needed for safety; remove excess waste beyond the 55-gallon (or acute) limit within three consecutive calendar days; move excess waste only to a central accumulation area, permitted storage, or an off-site facility rather than another SAA; apply either a one-quart liquid or one-kilogram solid limit for acute hazardous waste; mark every SAA container with the words “Hazardous Waste” plus one of five hazard identifiers (characteristic, DOT label/placard, OSHA pictogram, or NFPA 704); and include all SAA locations and waste descriptions in the facility’s Quick Reference Guide that is distributed to local emergency responders.
The author notes that these changes convert former guidance into binding federal regulation, heighten labeling and contingency-plan burdens (especially for facilities with numerous or frequently changing SAAs), and create new opportunities for violations and penalties, underscoring the value of specialized RCRA compliance assistance.
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