EPA Updates to Hazardous Waste Regulations FAQs

The objectives of the Hazardous Waste Generator Improvement 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).

The rule took effect at the federal level in June of 2017. It does not take effect in Florida until the Florida State Legislature adopt the rule officially. The state must adopt the rule by June 2018. Because of the somewhat open timeline, UF EH&S is beginning implementation immediately.

The Hazardous Waste Generator Improvement Rule reorganized the hazardous waste regulations to make them more understandable and strengthened some requirements to enhance protection of human health and the environment. The regulations are strengthened in three main areas:

  • Emergency Preparedness: requirements are extended to all areas of hazardous waste accumulation including SAAs. These include a fire alarm or internal communication device, a portable fire extinguisher, a communication device such as telephone (cell phone) or two way radio in order to summon help if necessary and spill response equipment appropriate for the waste accumulated (a spill kit).
  • Container Labeling: Hazardous waste labeling must include an indication of the hazard(s) present.
  • Hazardous Waste Determination: This must be made by the generator at the point of generation (in your lab).
The changes apply to all UF areas that generate hazardous waste.

Staff will have very few new responsibilities.

  • Emergency Preparedness:Under current UF policy, all of the required emergency preparedness equipment is either in place or already a requirement. Under the updated Satellite Accumulation Area Guidelines, staff should be aware of the location of emergency preparedness equipment.
  • Container Labeling:The primary change will be the transition to the new Hazardous Waste Label. All labs must transition immediately to the new hazardous waste label format which requires an indication of the waste hazard. As before you may generate your own labeling but it must follow the updated format.Original product containers determined to be hazardous waste must also be labeled using the new format.

    In lieu of using the yellow Hazardous Waste Label, the words “Hazardous Waste” be added to the original label as well as an indication of the chemical hazard. Many original product labels include words such as “Corrosive”, ”Flammable”, “Poison” or pictograms illustrating the pertinent hazard. These are acceptable indications of chemical hazard.
  • Hazardous Waste Determination:Proper labeling is based on an accurate waste determination. Hazardous waste generators must already determine whether the waste generated is an EPA Listed Waste or an EPA Characteristic Waste. When you place a Hazardous Waste label on the waste container you are designating it as hazardous waste. The change comes in the fact that you must make this determination for both byproduct waste (spent/mixed) and unwanted or unusable original products designated as waste.
Based on your hazardous waste determination, check any of the five categories that apply (Flammable, Oxidizer, Corrosive, Reactive and Toxic)
Check all hazards that apply.
Be sure to complete the annually required training for the identification and management of Hazardous Materials through the myTraining system course "EHS809". If you still can’t make that determination from the original container, the Safety Data Sheet (SDS), or product web search, the safest course of action is to consider it as hazardous and mark it “Toxic”. Contact EH&S for assistance in making a waste determination.

The new Hazardous Waste labeling requirements will also apply to all UF off-campus locations. Preparedness, Prevention and Emergency Procedures Requirements will impact off-campus operations differentially based on their hazardous waste generator status. Currently hazardous waste generators are designated as Large Quantity Generator (LQG), Small Quantity Generator (SQG), and Conditionally Exempt Small Quantity Generator (CESQG). Under the new rule, CESQG will be retitled “Very Small Quantity Generator” or VSQG. Most off-campus facilities fall in the VSQG classification which will be impacted minimally. The rule changes also include increased flexibility for VESQG and SQG facilities which allows them a temporary higher generator status in the event of an unplanned waste generation event (clean-out or spill). This flexibility is only available if the state adopts that portion of the rule. A summary of the changes affecting the off-campus locations can be found at Notice of EPA Changes to Hazardous Waste Regulations