March 2021
S&R of the Sun
This issue I focus solely on the USEPA regulations applicable to a small quantity generator (SQG) of hazardous waste. Specifically, the regulations of 40 CFR 262.16(b)(8-9) that mandate a SQG prepare for, prevent, and respond to hazardous waste emergencies at their facility.

If you have no interest in these regulations, I hope you can forward this newsletter to someone who might be. Next month I'll go back to spreading the topics around between HazMat transportation and waste management.


Preparedness, Prevention, and Emergency Procedures for a Small Quantity Generator of Hazardous Waste
A small quantity generator of hazardous waste (SQG) is required by USEPA to have certain equipment and procedures in place to prevent emergencies from happening and to respond to them when they do.

Requirements include: identify an emergency coordinator, maintain specific equipment, and ensure access to that equipment by personnel. If that wasn’t enough, these long-standing regulations were changed by the Generator Improvements Rule.

If you are a SQG in a state that has, or will, adopt the Generator Improvements Rule, you must read this series of articles to discover your new compliance requirements.

Each article in this newsletter addresses a separate requirement of this revised regulation.

Back in August of 2020, I dedicated an entire newsletter to the regulations applicable to the large quantity generator (LQG). You can read those articles here.
Maintenance and Operation
The regulations were revised to be applicable to more areas of the SQG’s facility. Make certain you are aware of the significance of this change. Read about it here.
Required Equipment
No change in the required equipment but changes to the applicable areas of the SQG where this equipment must be located. Read this!
Testing and Maintenance of Equipment
No change from prior to the Generator Improvements Rule. A quick read and pretty simple to comply.
Access to Emergency Communication
Read this! The addition of a few words “direct or unimpeded” emphasizes USEPA’s new requirement for “immediate access” to emergency communication devices.
Required Aisle Space
No change of any significance. But, are you aware of the required aisle space you must maintain to any area of your facility? If not, read on…
Arrangements with Local Authorities
Important and revised by the Generator Improvements Rule. You must read this!
Emergency Coordinator
No significant changes by the Generator Improvements Rule but a lot of critical information about who can be an Emergency Coordinator at a SQG. Be sure to check this out!
Post Emergency Information
Changed by the Generator Improvements Rule to clarify where the information is to be posted at the SQG and what information to include. Don’t miss this one!
SQG Training
The SQG must “ensure” its employees are “thoroughly familiar” with how to handle hazardous waste and how to respond to an emergency. I say training is how to achieve this. Read the article and decide for yourself.
Emergency Procedures
There are specific response actions a SQG must take in the event of emergencies such as spill, fire, or a release to the environment. Make certain your response is correct.
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2021 Upcoming Webinars
USEPA Hazardous Waste (RCRA) March 22nd
USDOT HazMat Employee April 5th

USEPA Hazardous Waste (RCRA) April 19th
USDOT HazMat Employee May 10th

Register now by clicking on the date above.

Or, contact me to make arrangements for a site-specific webinar scheduled at your convenience.
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Daniels Training Services
A different kind of training
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.