Hazardous Waste Decoded

Providing information and policy updates on hazardous waste management

On September 1, a number of changes to Wisconsin’s hazardous waste management rules went into effect.  The changes will affect most businesses that generate or handle hazardous wastes in the state and are intended to streamline certain aspects of the rules while making them more protective of public health and the environment.

The majority of the hazardous waste requirements in state statutes and rules reflect mandates contained in the federal RCRA and federal regulations that Wisconsin hazardous waste rules must reflect. 

The hazardous waste administrative rule revisions include three major federal initiatives: Generator Improvement Rule, Subpart P Hazardous Waste Pharmaceutical Rule and Definition of Solid Waste Rule. These federal rules will now be incorporated in the state rules and facilities must operate under these changes.

To the extent possible, the department has adopted equivalent content and format of the promulgated federal regulations. The rule package passed Legislative review and has an effective date of September 1, 2020. Hazardous waste administrative code (rules) can be found on the DNR’s Hazardous waste resources webpage: https://dnr.wisconsin.gov/topic/Waste/HWResources.html

Key changes include container labeling, renotification of SQG status every four years, LQG contingency plans, hazardous waste generator standards and more. EPA has updated two fact sheets outlining the rule changes, available on EPA’s website:

Requirements for Very Small Quantity Generators of Hazardous Waste

https://www.epa.gov/hwgenerators/fact-sheet-requirements-very-small-quantity-generators-hazardous-waste

Requirements for Large Quantity Generators of Hazardous Waste

https://www.epa.gov/hwgenerators/fact-sheet-requirements-large-quantity-generators-hazardous-waste

The hazardous waste program is creating and updating guidance documents to help people understand the new rules. Listed is a partial list of topics that our guidance documents will address: waste determination and record keeping; container and tank labeling and marking; LQG consolidation of VSQG hazardous waste (new); episodic generation notification (new); Hazardous secondary materials and legitimate recycling (new); 50-foot setback for waste accumulation (new); Satellite accumulation; LQG closure requirements for CAA and facility (new); Subchapter P Hazardous Waste Pharmaceuticals (new).

Once the guidance documents have been finalized, the department will offer an online webinar to provide an overview of the new guidance documents, explore the redesigned web site, and review the updated inspection forms to facilitate self-auditing.  The webinars are scheduled for Wednesday, November 11 (Updated web site, guidance document and inspection forms) and Wednesday, November 18 (Subchapter P Hazardous Waste Pharmaceuticals).

FET will also cover this information at the Environment 2020 Virtual Conference, watch for details!