Notice of EPA Updates to Hazardous Waste Regulations

Recent Changes to the United States EPA and State of Florida DEP hazardous waste generator regulations will impact the University of Florida operations wherever hazardous waste is generated. The objectives of the Hazardous Waste Generator Improvement Final Rule are to streamline the current hazardous waste regulations and to enhance environmental protection by providing greater clarification of and in some cases strengthening requirements for management of hazardous waste (mandatory changes). In some cases, the new rules may provide greater flexibility in hazardous waste management (optional changes).

Impacts to UF Main Campus:

Hazardous Waste Container Labeling Requirements

Under the new rule, all hazardous waste containers must be marked with the words “Hazardous Waste” and an indication of the hazard(s) associated with the waste contents (i.e. Flammable, Oxidizer, Corrosive, Reactive, Toxic, etc.).

Implementation:  UF EH&S has updated to a new Hazardous Waste Label. The new labels will be required on both waste mixture containers and unwanted product containers. The new labels and labeling requirements will be introduced via mass communication, instructional poster, the main EH&S webpage, and waste pick-up request form page. Introduction and explanation of the new requirements will be integrated into the Hazardous Waste Management training courses and the new requirements will be reinforced by Waste Management Facility staff with each waste collection.

Preparedness, Prevention and Emergency Procedures Requirements

Previously required only for the EH&S Waste Management Facility, these requirements now extend to all hazardous waste accumulation areas including all laboratory/workshop Satellite Accumulation Areas.

Implementation: The required emergency equipment such as fire alarms, fire extinguishers and communication devices are already provided in nearly all labs and workplaces. They must exist within the area served by the Satellite Accumulation Area. To further compliance, the Preparedness, Prevention and Emergency Procedures Requirements have been incorporated into the Satellite Accumulation Area Requirements, the Satellite Accumulation Area Inspection process and the Hazardous Waste Monthly Self Audit.

Impacts to Off-Campus UF Facilities (IFAS Research and Education Centers, Teaching Units, Research Laboratories, Clinics, etc.

Currently off-campus facilities are designated as Large Quantity Generator (LQG), Small Quantity Generator (SQG), and Conditionally Exempt Small Quantity Generator (CESQG). Under the new rule, CESQG is retitled “Very Small Quantity Generator” or VSQG. Since most off-campus facilities fall in the VSQG classification, there will be minimal impact. The new Hazardous Waste labeling requirements will apply to all UF off-campus locations. Preparedness, Prevention and Emergency Procedures Requirements will apply only to off-campus generators who are SQG or LQG.
The rule changes also include increased flexibility for VESQG and SQG facilities which would allow a temporary higher generator status in the event of an unplanned waste generation event (clean-out or spill). This flexibility will only be available if the state adopts that portion of the rule. In order to simplify the requirements and their potential changes the current and new requirements are summarized below:

Summary of Changes to SQG and LQG Requirements

Requirement  Existing Generator Regulations  2017 Rule Changes
Satellite accumulation container marking/labeling The words “Hazardous Waste” or other words that identify the contents The words “Hazardous Waste” and an indication of the hazard(s) of the contents
SQG/LQG re-notification requirements None  Beginning in 2021 and every 4 years thereafter, SQGs must re-notify EPA by September 1 using Form 8700-12.
LQGs must re-notify EPA by March 1 of each even-numbered year using Form 8700-12 as part of their biennial report.  
SQG/LQG 90/180/270-day accumulation unit marking/ labeling   Containers: The words “Hazardous Waste” and the accumulation start date Tanks: The words “Hazardous Waste”   Containers:

  1. The words “Hazardous Waste,”
  2. an indication of the hazard(s) of the contents
  3. the accumulation start date.

Tanks and containment buildings:The words “Hazardous Waste” and an indication of the hazard(s) of the contents.  

SQG/LQG preparedness and prevention requirements and emergency procedures Apply to 90/180/270-day accumulation areas  Apply to satellite accumulation areas and to 90/180/270-day accumulation areas 
SQG/LQG arrangements with local authorities and the properties of hazardous waste handled at the facility Must attempt to make arrangements, as appropriate, to familiarize police, fire departments, emergency response teams, emergency response contractors, equipment suppliers, and local hospitals with the layout of the facility and the properties of hazardous waste handled at the facility  Must attempt to make arrangements, as appropriate, to familiarize police, fire departments, emergency response teams, emergency response contractors, equipment suppliers, local hospitals, and the LEPC with the layout of the facility
SQG/LQG pre-transport marking requirements
  • DOT marking
  • For containers of ≤119 gal capacity: “HAZARDOUS WASTE—Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.”
  • Generator’s name, address, and EPA ID number
  • Manifest tracking number
  • DOT marking
  • For containers of ≤119 gal capacity: “HAZARDOUS WASTE—Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.”
  • Generator’s name, address, and EPA ID number
  • Manifest tracking number
  • EPA hazardous waste codes

 

“Episodic” LQG Status  Not available in Florida  If adopted, would provide a conditional, temporary LQG status for VSQGs or SQGs 

Source: McCoy & Associates White Paper: Changes to Hazardous Waste Generator Regulations

Additional information can also be found:
Hazardous Waste Labeling Requirements 
Hazardous Waste Satellite Accumulation Area Requirements
Hazardous Waste Monthly Self Audit Form
Frequently Asked Questions concerning the EPA Generator Improvements