March 14, 2018

EPA Answers Questions on the Generator Improvements Rule

EPA has published a frequent questions page on its website that addresses the hazardous waste generator improvements rule (GIR), which took effect at the federal level on May 30, 2017. [81 FR 85732] A few of the answers that the agency published caught our eye because they provide insight into the agency’s position on select issues:

State Adoption

States are required to adopt the more-stringent provisions of the GIR by July 1, 2018, or July 1, 2019 if the state regulatory process includes a legislative step. States are not required to adopt provisions that are less stringent than the previous regulations. EPA has clarified on this Q&A page what GIR provisions states must adopt by noting those that are more and less stringent.

More-stringent provisions, which must be adopted by states, include:

Less-stringent provisions, which states are not required to adopt, include:


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This document addresses issues of a general nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with the RCRA 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.