United States
Environmental Protection
Agency
March 1985
EPA/530-SW 85 005
• Retain manifests signed by the hazardous waste
facility for at least 3 years. (The facility will be
required to return a copy of the signed manifest to
the generator.)
• Notify EPA at least twice a year of any manifests
that are not returned by the facility.
Education/Assistance Program
Because the new RCRA provisions regulate a large
number of companies for the first time, EPA is
conducting an education/assistance program to
alert small quantity generators to their
responsibilities under federal law. The program is
in two phases, paralleling the two phases in which
the new RCRA will be implemented.
For the provisions that must be implemented by
August 1985, EPA will:
• Identify potential small quantity generators.
• Provide information—through EPA regional
offices, states and trade associations—to help small
quantity generators determine if they are affected
by the new regulations. This information will
identify wastes by product trade names, chemical
and slang names, or general descriptions; and will
correlate the waste with the appropriate
Department of Transportation identification
number wherever possible.
• Inform small quantity generators of the need to
prepare a Uniform Hazardous Waste Manifest to
accompany any waste they ship, and explain how
and where to obtain the appropriate manifest form.
For the final regulations—to be issued by March
31, 1986, or that take effect automatically on April
1, 1986, if EPA does not issue final regulations on
time—EPA must:
• Alert the small quantity generators to the new
regulations and the additional requirements.
• Provide them with complete instructions and
industry-specific information that will help them
in complying.
To help in carrying out this education/assistance
program, EPA is working closely with trade
associations, small business organizations, and
state and local government organizations.
Solid Waste and Emergency Response
&EPA Small Quantity
Hazardous Waste
Generators
The
New RCRA
Requirements
230 South Dearborn Street
ft U.S. GOVERNMENT PRINTING OFFICE: 1985—556-512/8690
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On November 8, 1984, amendments were
enacted strengthening the Resource
Conservation and Recovery Act (RCRA), the federal
law which protects human health and the
environment from improper waste management
practices. This new legislation—the Hazardous and
Solid Waste Amendments—makes many changes
in the national program which regulates hazardous
waste from the time it is generated to its final
disposition. The program is administered by the
U.S. Environmental Protection Agency (EPA)
through its Office of Solid Waste.
One of the new RCRA provisions directs EPA to
promulgate regulations for the generators of small
quantities of hazardous waste. Previously, EPA
regulated only those establishments generating
more than 1,000 kilograms (2,200 pounds) of
hazardous waste per month. Under the new law,
establishments that generate 100 kilograms (220
pounds, or roughly half a 55-gallon drum) but less
than 1,000 kilograms in a calendar month will
have to comply with those requirements which
cover the transportation and disposal of hazardous
waste.
Newly Regulated Businesses
EPA estimates that the new RCRA will increase the
number of federally regulated generators from
about 15,000 to well over 100,000 firms. An EPA
survey released in March 1985 suggested that more
than half of these small quantity generators fall
into one of five categories:
• Vehicle maintenance
• Manufacturing and finishing of metals
• Printing
• Photography
• Laundries and dry cleaners
Other industrial categories with a substantial
number of small quantity generators are: wood
preserving, analytical and clinical laboratories,
construction, and pesticide applicators.
The new federal requirements will have their
greatest impact on the waste management practices
of firms not now regulated by state hazardous
waste laws. At least 22 states currently impose
some degree of regulation on small quantity
generators.
U,S. Environmental Protection Agency
August 1985 Requirements
Starting in August 1985, small quantity generators
who ship their hazardous waste off their premises
must obtain and fill out parts of a Uniform
Hazardous Waste Manifest. This is a form that EPA
and the Department of Transportation (DOT)
currently require all regulated hazardous waste
generators to use when they ship hazardous
waste. The manifest provides a way to track a
shipment of hazardous waste from its origin to its
final disposal.
The manifest must accompany shipments of
hazardous waste made after August 5, 1985. The
manifest must include:
• The generator's name, address, and signature.
• The DOT description of the waste, including the
shipping name, hazard classification, and
identification number.
• The number and type of containers.
• The quantity of waste being transported.
• The name and address of the facility designated
to receive the waste.
March 31, 1986 Deadline
By March 31, 1986, EPA must issue final
regulations that protect human health and
environment from small quantities of hazardous
waste. At a minimum, the new regulations must:
• Require that hazardous waste from generators of
more than 100 kilograms per month must be
treated, stored, or disposed of at an approved
hazardous waste facility.
• Allow small quantity generators to store waste
on the premises of the establishment for up to 180
days without the need for a storage permit. The
period may be extended to 270 days for waste that
must be transported more than 200 miles, provided
that no more than 6,000 kilograms are stored.
If EPA fails to issue final regulations by March
31, 1986, hazardous waste from small quantity
generators automatically becomes subject to these
minimum requirements.
In addition, for waste shipped off-site, small
quantity generators will be required to:
• Include the name of the transporter cm the
manifest^] 7, F;,vironme< .-Cuon
[,..:-< on V, Library
230 South Dearborn Street
jCJaJcago. Illinois 60604
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