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Business and Policy Areas
Business and Policy Areas

EPA Proposes Revisions to Hazardous Waste Rules

October 5, 2015

On September 25, the Environmental Protection Agency (EPA) proposed a revision to its rules for generators of hazardous waste, including colleges and universities, under the Resource Conservation and Recovery Act (RCRA). The agency also proposed new rules for pharmaceutical waste.

According to the EPA, the changes to generator rules are needed to address gaps in the current regulations, provide greater flexibility, and reorganize the rules to make them easier to understand and improve compliance. Comments are due November 24.

Several provisions address items that have long been on higher education's wish list, such as allowing locations that generate only small amounts of hazardous waste to send it to a large quantity generator that is under the same control. This could simplify compliance for satellite locations and multi-campus systems.

The proposal would also prevent occasional or episodic increases in the amount of waste generated from forcing a small quantity generator into a different regulatory regime. A similar provision was promulgated for academic laboratory waste in 2008.

The extensive revision also addresses a number of other topics that will impact many colleges and universities, including:

  • Classification of entities that generate both acute and nonacute hazardous waste in the same month
  • Mixing of hazardous and nonhazardous waste
  • Labeling and marking requirements for containers, tanks, and buildings
  • Notification
  • Preparedness planning requirements

Waste Pharmaceuticals

The EPA also published a separate notice of proposed rulemaking that focuses on pharmaceutical waste at hospitals and other healthcare facilities. This proposal would create a new framework for managing pharmaceutical waste that meets the definition of hazardous waste under RCRA, including unused medications and contaminated containers. The proposed standards, which would be mandatory, set out separate requirements for waste medications that may be accepted by reverse distributors for credit and those that are not. The comment deadline for the pharmaceutical rules is also November 24.


Anne Gross
Vice President, Regulatory Affairs