Changes Coming to Hazardous and Universal Waste Management in Ohio
Hazardous waste generator improvements are coming! These changes are good, but will require generators here in Ohio to review their hazardous waste programs and be prepared to incorporate these changes by May 2019.
New definitions, requirements and regulatory references have been established for all categories of waste generators and also changing the smallest waste generator category known as Conditionally Exempt Small Quantity Generators (CESQGs), to now be called Very Small Quantity Generators (VSQGs). All the changes are far too extensive to cover in a short blog, but some of the most significant changes will be covered.
Satellite Accumulation Point Management
EPA has revised quantity limits for acute hazardous wastes (1 qt for liquids and 1 kg for solids) at satellite accumulation points as well as marking requirements on hazardous waste containers at satellite accumulation points. Containers must still be marked with the words “Hazardous Waste” but now also have markings indicating the “Hazards” of the waste.
For Small and Large Quantity Generators, Satellite Accumulation Points must now meet generator-specific emergency preparedness and planning requirements, which previously only applied to a generators 90-day or 180-day centralized storage areas.
Emergency Preparedness and Planning
Requirements pertaining to emergency preparedness have been expanded to include posting emergency response information “next to telephones or in areas directly involved in waste generation and accumulation of hazardous waste”. Further, all Large Quantity Generators (LQGs) will be required to prepare and submit to local first responders or the Local Emergency Planning Committee (LEPC) a Quick Reference Guide.
Many generators have been forced to scramble to meet higher generator category requirements or take the risk and liability of being in non-compliance when unplanned (or even planned) hazardous waste generation causes the generator to exceed their normal generator category limits. Under the new rulemaking, EPA allows for a one time episodic hazardous waste generation event (planned or unplanned) allowing a VSQG or SGQ to remain in their normal waste generator category.