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Hazardous and Industrial Waste Compliance News

With the Hazardous Waste Generator Improvements Rule, EPA provided relief for so-called "episodic hazardous waste generation" events - occasions when a facility that is usually a small quantity generator (SQG) or a very small quantity generator (VSQG, formerly conditionally exempt small quantity generator) of hazardous waste generates more than its monthly limits, potentially elevating the facility into a higher generator category. ...

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On February 22, 2019, EPA published new rules for management of hazardous waste pharmaceuticals that will affect healthcare facilities, including hospitals, clinics, dentist offices, nursing care facilities, veterinary clinics, outpatient care centers, pharmacies and drug stores, even supermarkets, that generate, accumulate, or otherwise handle prescription pharmaceuticals. ...

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In a notice of proposed information collection request published on February 8, 2019, the EPA has indicated that it is considering revisions to the RCRA Hazardous Waste Manifest, both electronic ("e-Manifest") and paper versions....

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The Court of Appeals for the DC Circuit has vacated provisions of EPA's 2015 Definition of Solid Waste Rule which addressed recycling of hazardous secondary materials (i.e., spent materials, byproducts and sludges). The court's majority took issue with (1) one of four tests to demonstrate that recycling by or under the control of the generator was legitimate, and not a "sham" effort to disguise disposal, and (2) the "Verified Recycler Exclusion", which excluded recyclable secondary materials from the definition of solid waste and therefore from regulation as hazardous waste, provided that the recycling facility has a hazardous waste facility permit or a variance from permit requirements granted by EPA or the State.

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