What Is RCRA? Understanding the Resource Conservation and Recovery Act
The Resource Conservation and Recovery Act (RCRA) is a foundational U.S. environmental law that governs the proper management of hazardous and non-hazardous solid waste. Enacted in 1976, RCRA gives the Environmental Protection Agency (EPA) the authority to oversee waste management "from cradle to grave" — from generation through transportation, treatment, storage, and final disposal.
RCRA regulations are codified under 40 CFR Parts 239–282 and apply to a wide range of industries that generate, store, transport, or dispose of hazardous waste materials.
A Brief History of RCRA
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1965: The Solid Waste Disposal Act is passed to address growing concerns over solid waste management.
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1976: Congress enacts the Resource Conservation and Recovery Act (RCRA), expanding federal authority and introducing hazardous waste controls.
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1984: Federal Hazardous and Solid Waste Amendments (HSWA) strengthen the law, emphasizing hazardous waste minimization and phasing out land disposal.
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1992: The Federal Facility Compliance Act increases RCRA enforcement at federal installations.
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1996: The Land Disposal Program Flexibility Act introduces more flexible requirements for specific low-risk waste streams.
What Are RCRA Subtitle C and Subtitle D?
Subtitle C – Hazardous Waste Management
Subtitle C outlines strict requirements for managing hazardous waste, including:
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Identification and classification of hazardous wastes
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Proper storage, treatment, and disposal procedures
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Transportation standards
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Facility permitting and reporting requirements
Industries covered under Subtitle C include:
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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 are found in 40 CFR Parts 260–273.
Subtitle D – Non-Hazardous Solid Waste Management
Subtitle D governs the management of non-hazardous solid wastes and bans the open dumping of waste. It focuses on:
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Municipal solid waste landfills
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Industrial non-hazardous waste landfills
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State and local waste management programs
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Corrective actions for landfill releases
Subtitle D aims to protect public health and the environment through responsible solid waste management practices.
Categories of Hazardous Waste Generators
Hazardous waste generators are divided into three categories based on the amount of hazardous waste they produce monthly:
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 acute hazardous waste
Small Quantity Generators (SQG)
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Generate between 220 and 2,200 pounds of hazardous waste per month
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May store waste for up to 180 days (or 270 days if the facility is over 200 miles from a TSD site)
SQG storage requirements:
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No more than 13,227 pounds (6,000 kg) stored onsite
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Use compliant containers (e.g., 55-gallon drums, appropriate tanks)
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 acute hazardous waste
LQG storage requirements:
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May store waste onsite for up to 90 days before shipment
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Must comply with broader requirements, including contingency planning and biennial reporting
Important: If a generator exceeds allowed storage times or volumes, they may be reclassified as a hazardous waste storage facility, triggering much more stringent permitting under RCRA regulations.
Why RCRA Compliance Matters
Non-compliance with RCRA requirements can result in severe penalties, including:
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Fines up to $84,874 per day, per violation (as of 2025 updates)
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Potential environmental remediation costs
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Legal liability and reputational damage
Maintaining compliance through proper training, waste management procedures, and facility audits protects your workforce, the environment, and your bottom line.
Final Thoughts
RCRA remains a critical pillar of environmental and worker safety regulations in the United States. Whether you generate hazardous waste in small amounts or manage large-scale disposal operations, understanding and complying with RCRA is essential to responsible business operations.
At Compliance Solutions, we offer RCRA Hazardous Waste Training for employees at all levels to help organizations meet their obligations and maintain best-in-class environmental standards.
