Frequent Questions

How does a hazardous waste generator certify compliance with the waste minimization requirements in RCRA §1003(b)?

Hazardous waste generators must certify compliance with waste minimization requirements in RCRA §1003(b) when preparing a hazardous waste manifest.

Large quantity generators must certify that they have a program in place to reduce the volume and toxicity of the hazardous waste they generate; small quantity generators must certify that they have made a good faith effort to minimize their waste generation.  Generators shall include the following six basic elements in their waste minimization program:  top management support, characterization of waste generation and waste management costs, periodic waste minimization assessments, appropriate cost allocation, encouragement of technology transfer, and program implementation and evaluation (58 FR 31114, May 28, 1993).

Additional guidance on the generator's certification on the manifest is available in the following documents:

Monthly Call Center Report Question; June 1997 (RCRA Online #12932)
Memo, Shapiro to St. John; July 18, 1994 (RCRA Online #11855)
Memo, Browner to Dingell; August 11, 1993 (RCRA Online #11764) (PDF, 24K)
Memo, Williams to States; October 20, 1986 (RCRA Online #12767)
Memo, Williams to Dauphin; April 28, 1986 (RCRA Online #12629)
Memo, Williams to Fixter; February 6, 1986 (RCRA Online #12559)
Monthly Call Center Report Question; October 1985 (RCRA Online #12470)
Memo, Williams to Deever; October 17, 1985 (RCRA Online #11108) (PDF, 7K)

Additional information regarding waste minimization is available at the following URL:

http://www.epa.gov/epawaste/hazard/wastemin/

Note: On November 28, 2016, EPA published the Hazardous Waste Generator Improvements Final Rule, which makes several revisions to the hazardous waste generator regulations. These revisions may affect the information provided in this FAQ. The final rule and additional information, including a fact sheet, frequent questions, and a webinar recording and slides, are available at www.epa.gov/hwgenerators/final-rule-hazardous-waste-generator-improvements.

The Hazardous Waste Generator Improvements Final Rule is effective on May 30, 2017; however, implementation in a particular state depends on the state’s authorization status. A discussion of the effect that this final rule will have on state authorization is available on page 85801 of the rule. Information about how the rule will affect the requirements in this FAQ in a particular state is best obtained from the state hazardous waste program. A list of state hazardous waste programs is available at www.epa.gov/hwgenerators/links-hazardous-waste-programs-and-us-state-environmental-agencies.

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