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
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         230  South  Dearborn Street
	jCJaJcago.  Illinois  60604

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