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Counting Hazardous Waste for the Generator Category Determination
After completing the hazardous waste determination as required by USEPA regulations at 40 CFR 262.11, the most fundamental responsibility of the generator of a waste is to count the hazardous waste it generates each month and determine its hazardous waste generator category.
From the Federal Register publication of the final rule (81 FR, 11.28.16, 85755):
A generator must correctly count the quantity of hazardous waste that it generates in order to determine its generator category.
Despite its importance, the requirements for counting hazardous waste and determining generator category were not presented in a clear and distinct manner. That problem was corrected by the Generator Improvements Rule. The purpose of this article is to identify and explain the requirements of 40 CFR 262.13 for the counting of hazardous waste and the determination of hazardous waste generator category as revised by the Generator Improvements Rule.
Important note: As 40 CFR 262.13(e) indicates, after a generator has counted its hazardous waste and determined its generator category it must comply with the applicable regulations for that category. If you have any questions about the hazardous waste determination, determining your hazardous waste generator category, or any of the responsibilities of a hazardous waste generator.Contact me for further information.
Comparison of Changes to Regulations for Generator Category Determination
In the previous article, I review in detail the Federal USEPA regulations of 40 CFR 262.13 and its mandate to a generator to count the hazardous waste it generates and to determine its hazardous waste generator category. as those regulations were changed by the Generator Improvements Rule.
While the in-depth analysis of that article will assist you in understanding and complying with this very important regulation, it may also be of assistance to you to see – side-by-side – the applicable regulations before and after the changes of the Generator Improvements Rule.
I provide training and consulting services to equip your team – whether it’s just you or a group of employees – to safely ship, receive, transport or dispose of hazardous materials and waste.