Framework Safety & Workforce
EPA RCRA
The Resource Conservation and Recovery Act (RCRA) is the US federal law governing hazardous waste from generation to disposal.
The EPA's hazardous waste generator regulations in 40 CFR Part 262 sort generators into three categories by monthly quantity: very small quantity generators (100 kg or less per month), small quantity generators (more than 100 kg but less than 1,000 kg), and large quantity generators (1,000 kg or more, or more than 1 kg of acutely hazardous waste).
Obligations scale with the category: waste determinations, EPA identification numbers, accumulation time and container rules, manifests, biennial reports, personnel training, preparedness and prevention, and for large quantity generators a written contingency plan.
The 2016 Generator Improvements Rule reorganized these rules and most states have adopted it, with some running stricter programs.
In writing, a large quantity generator must keep hazardous waste determinations and their basis, a contingency plan (with a quick reference guide) distributed to local emergency responders, a personnel training program with job descriptions and training records, inspection logs for accumulation areas, manifests and land disposal restriction notifications, biennial reports, and closure documentation.
Small quantity generators have lighter written requirements but still need emergency information posted and basic training. State or EPA inspectors check the paperwork against what they see on the floor.
Who has to comply
Any facility that generates hazardous waste as defined in 40 CFR Part 261, from manufacturers and laboratories to hospitals, universities, and auto shops. The generator category is determined monthly by quantity, and episodic generation rules can apply. Transporters and treatment, storage, and disposal facilities have their own parts (263 through 270).
What the assessor asks to see
EPA identification number and site identification form; hazardous waste determinations and supporting analysis or knowledge; generator category calculation records; accumulation area inspection logs; container labeling and accumulation start dates; satellite accumulation area controls; manifests and exception reports; land disposal restriction notifications; biennial reports; contingency plan, quick reference guide, and proof of submission to local responders; emergency coordinator designation; personnel training program description, job titles, and training records; preparedness and prevention equipment records; closure notifications and documentation; universal waste and used oil records where applicable; air emission standards records for tanks and containers where applicable.
Where the requirement sits: 40 CFR 262.17(a)(6) contingency plan; 262.17(a)(7) training programme and records; 262.16 SQG training
Generator categories and written requirements
Very small quantity generators have minimal written obligations beyond waste determinations. Small quantity generators must post emergency information by the phone, train employees in waste handling and emergency procedures, and keep manifests and inspection records.
Large quantity generators must have a written contingency plan with a quick reference guide, a documented training program with annual refreshers and records kept for current staff and three years after departure, weekly inspection logs, and biennial reporting. Authorized states can and do add requirements, so check the state program that applies.
What AllyMatter does here
Controls the contingency plan and training programme document; holds training records.
AllyMatter publishes this site.
Assessors
Who assesses EPA RCRA
State environmental agency inspectors in authorized states, and EPA regional inspectors (government inspection and enforcement). No certification exists. (government enforcement).
No firm has claimed a EPA RCRA assessor listing yet. Claim yours →
Consultants
Who helps with EPA RCRA
A large environmental consulting ecosystem exists. Consultants perform waste determinations, set up accumulation areas and labeling, write the contingency plan and training program, deliver required annual training, prepare biennial reports and manifests, run compliance audits, and support responses to inspections and enforcement.
Engagement shape ranges from one-time program setup to ongoing retained compliance support.
Firms that name this framework in their own material. Listings we have not verified yet come from public filings and partner lists. Each firm can confirm its own.
No firm has claimed a EPA RCRA consultant listing yet. Claim yours →
Software
Tools for EPA RCRA
Tools that name this framework in their own material.
Related reading
- Final rule: hazardous waste generator improvementsA waste handler's read of the sixty-odd changes, including episodic generation, container hazard marking and the contingency plan quick reference guide.Veolia North America
- Regulation of laboratory wasteProfessional society view on how generator rules land on laboratories, including the satellite accumulation and training obligations.American Chemical Society
Independent third-party explainers, chosen by hand. Not affiliated with this site and not paid placements. All links are nofollow.
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From the publisher
Run the Policy Side of EPA RCRA in AllyMatter
Approve the policies EPA RCRA asks for, keep every version, and record a named acknowledgment from each person who has to read them.