Regulatory Requirements

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LQGs and SQGs are subject to regulations that require each generator to

1. Identify and count waste.

3. Comply with accumulation and storage requirements (including requirements for training, contingency planning, and emergency arrangements).

4. Prepare the waste for transportation.

5. Track the shipment and receipt of such waste.

6. Meet recordkeeping and reporting requirements.

CESQGs are not subject to most of the generator requirements applicable to LQGs and SQGs, but they must identify their hazardous waste, comply with storage limit requirements, and ensure waste treatment or disposal in an on-site or off-site

1. Permitted or interim status hazardous waste TSDF

2. State hazardous waste facility

3. State permitted, licensed, or registered solid waste disposal facility

4. State municipal solid waste landfill (MSWLF)

5. Recycling facility

6. Universal waste facility.

Any person importing hazardous waste into the United States from a foreign country is subject to hazardous waste generator standards. RCRA also contains specific requirements for hazardous waste exports. Importers and exporters must also comply with the provisions of international trade treaties, such as the Basel Convention and the Organization for Economic Cooperation and Development (OECD) Council Decision.

Because farmers disposing of certain pesticide wastes on their own land are subject to regulation under both RCRA and FIFRA, RCRA specifically excludes such farmers from the generator requirements.

12.6.2 Hazardous Waste Transporters

Hazardous waste transporters play an integral role in the cradle-to-grave hazardous waste management system by delivering hazardous waste from its point of generation to its ultimate destination. Since such transporters are moving regulated wastes on public roads and highways, rails, and waterways, they are regulated not only by RCRA, but by DOT standards as well. To avoid regulatory discrepancies and redundant regulations, hazardous waste transporter regulations were developed jointly by U.S. EPA and DOT.

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