What Is RCRA? Understanding the Resource Conservation and Recovery Act
The Resource Conservation and Recovery Act (RCRA) is a key environmental law in the United States that governs the management of both hazardous and non-hazardous solid waste. Enacted in 1976, RCRA provides the U.S. Environmental Protection Agency (EPA) with the authority to oversee the "cradle-to-grave" lifecycle of hazardous waste—from its generation to its ultimate disposal.
RCRA regulations are found in Title 40 of the Code of Federal Regulations (CFR), Parts 239–282, and are critical for facilities involved in waste generation, treatment, transportation, storage, and disposal.
A Brief History of RCRA
RCRA was signed into law on October 21, 1976, building on the earlier Solid Waste Disposal Act of 1965. Over time, it has been strengthened through several key amendments:
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1984 – Federal Hazardous and Solid Waste Amendments (HSWA): Introduced land disposal restrictions, waste minimization strategies, and corrective action requirements.
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1992 – Federal Facility Compliance Act: Increased regulatory enforcement of hazardous waste management at federal facilities.
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1996 – Land Disposal Program Flexibility Act: Allowed for greater flexibility in the management of certain low-risk hazardous wastes.
RCRA Subtitle D – Non-Hazardous Waste Management
RCRA Subtitle D governs the management of non-hazardous solid waste and prohibits the open dumping of waste. It establishes minimum federal standards for:
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Municipal Solid Waste Landfills (MSWLFs)
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Industrial Non-Hazardous Waste Landfills
Facilities under Subtitle D must comply with regulations concerning:
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Location restrictions
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Groundwater monitoring
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Corrective action for releases
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Closure and post-closure care
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Financial assurance for long-term compliance
States are primarily responsible for implementing and enforcing Subtitle D regulations, with EPA oversight.
RCRA Subtitle C – Hazardous Waste Management
Subtitle C provides a comprehensive framework for managing hazardous waste from its point of generation through transportation, treatment, storage, and disposal.
Subtitle C regulations apply to:
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Hazardous Waste Generators
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Hazardous Waste Transporters
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Treatment, Storage, and Disposal Facilities (TSDs)
Regulations under Subtitle C include:
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Waste identification and classification
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Standards for generator management
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Requirements for permits, reporting, and tracking
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Employee training and emergency preparedness
Hazardous Waste Generator Categories
Hazardous waste generators are categorized based on the quantity of hazardous waste produced each month. All generators must comply with EPA regulations and training requirements under RCRA.
Very Small Quantity Generators (VSQG)
(formerly known as CESQG – Conditionally Exempt Small Quantity Generators)
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Generate less than 220 pounds of hazardous waste per month
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Generate less than 2.2 pounds of acutely hazardous waste
Key Requirements:
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Proper labeling and safe accumulation
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May not accumulate more than 2,200 pounds onsite at any time
Small Quantity Generators (SQG)
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Generate between 220 and 2,200 pounds of hazardous waste per month
Key Requirements:
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May accumulate waste onsite for up to 180 days (or 270 days if the TSD facility is over 200 miles away)
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May not exceed 13,227 pounds of waste onsite
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Must use appropriate containers (e.g., drums or tanks)
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Must follow EPA contingency planning and personnel training requirements
Large Quantity Generators (LQG)
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Generate more than 2,200 pounds of hazardous waste per month
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Generate more than 2.2 pounds of acutely hazardous waste
Key Requirements:
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May accumulate waste onsite for up to 90 days
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Must comply with full contingency planning, emergency procedures, and reporting
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Must ensure proper labeling, documentation, and use of compliant containers
⚠️ Failure to meet these criteria may result in reclassification as a hazardous waste storage facility, which requires additional permits and regulatory oversight.
Why RCRA Compliance Matters
Non-compliance with RCRA regulations can result in significant civil and criminal penalties, reputational damage, and environmental harm. In 2024, the maximum civil penalty for RCRA violations exceeds $120,000 per violation, per day (adjusted annually).
Businesses can reduce risk and maintain compliance through proper training, facility audits, and adherence to EPA and state-specific RCRA programs.
Want to stay compliant?
Compliance Solutions offers RCRA Hazardous Waste Management Training in online, onsite, and virtual formats, tailored for both small and large waste generators.
