July 17, 2025
California’s DTSC 2025 Hazardous Waste Priorities
In April 2025, California’s Department of Toxic Substances Control (DTSC) hosted a webinar discussing its regulatory priorities for the year. The presentation focused on adopting regulations to align the California hazardous waste program with the federal RCRA regulations. While a recording of the webinar has not been made available by the department, the presentation slides are available on our website. Below is a summary of the provisions on DTSC’s agenda.
DTSC’s 2025 Regulatory Priorities
Provision | Effect | Important dates |
|---|---|---|
Manifest exemption for contiguous properties—§262.20(f) | Adds new §66262.20(f), allowing a generator to transport hazardous waste between contiguous properties (i.e., touching along a boundary or point) under the control of the same person without a manifest; see RO 14696 for guidance | Estimated public notice— |
Manufactured gas plant waste exemption—§261.24(a) | Adds the phrase “except manufactured gas plant waste” to the beginning of §66261.24(a)(1) [see Association of Battery Recyclers, Inc. et al. vs. EPA (U.S. Court of Appeals, D.C. Circuit; Docket No. 98-1368; April 21, 2000)]] | Estimated effective date— |
Industrial alcohol exemption—§261.6(a)(3)(i) | Provision has already been adopted as a temporary emergency rule in §66261.6(a)(3)(D); a new regular rule would make the provision permanent | Estimated public notice— |
K-listings from various industries—§261.32 | Adds K169, K170, K171, K172, K176, K177 K178, and K181 to §66261.32; these wastes are already regulated in California under HSC 25117(b) and 25120.2 | Estimated effective date— |
e-Manifest third rule—multiple sections | Adds the 2024 e-Manifest third rule in its entirety; see previous article for scope of the rule | Estimated effective date— |
Hazardous waste pharmaceutical rule—Part 266, Subpart P | Adds the 2019 hazardous waste pharmaceuticals rule in its entirety; see previous article for scope of the rule | Estimated effective date— |
Generator improvements rule (GIR) optional provisions—multiple sections | GIR provisions that made RCRA less-stringent currently being considered for adoption, includes regulations on hazardous waste determinations, episodic generation, very small quantity generators | Estimated effective date— |
Conditional exemption for undeployed airbags—§261.4(j) | Provision had been adopted as a temporary emergency rule in §66261.4(j) but has since expired; a new regular rule would make the provision permanent | Estimated effective date— |
Source: McCoy and Associates, Inc.
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This document addresses issues of a general nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with the environmental regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.
