As we informed you in the last blog, the EPA Administrator signed the proposed Hazardous Waste Generator Improvements Rule on August 31, 2015. A pre-publication copy has been circulated and published at The proposed changes will have an effect for large, small and conditionally exempt small quantity generators. The proposed rule was published in the Federal Register on September 25, 2015.

Comments on this proposal will be accepted for 60 days following publication of this rule in the Federal Register. Comments are due to EPA by November 24, 2015. It is Docket No. EPA-HQ-RCRA-2012-0121. Comments can be submitted electronically at!submitComment;D=EPA-HQ-RCRA-2012-0121-0001.

Karen Thompson is a Senior Project Manager at Smith Management Group. Karen can be reached at