Real Updates to RCRA

RCRA was signed by President Ford on October 21, 1976, and as such is approaching its 40^th birthday.  Many of us are busy ordering black balloons and streamers for the celebration.  EPA published a revised  overhaul of the RCRA generator standards in the September 25, 2015 Federal Register as a proposed rule.  The comment period closed on this rule on December 24, 2015.  EPA is calling this initiative “Hazardous Waste Generator Improvements Rule.”  We understand the purpose behind this proposed rule is to incorporate 30 years of experience into the rules.  The rewriting and reorganization of the rule will update all of the regulatory references that we HSE professionals have memorized over the years.  We will walk through the proposed changes and even give an update on the status of e-manifesting.