MassDEP proposes key updates to EPA's Hazardous Waste Generator Improvement Rule

The Massachusetts Department of Environmental Protection (MassDEP) held a meeting on April 11, 2025, to discuss proposed updates to the state’s hazardous waste regulations, specifically focusing on the adoption of key elements from the U.S. Environmental Protection Agency's (EPA) Hazardous Waste Generator Improvement Rule (GIR) established in 2016.

The meeting began with an overview of the GIR, which introduced over 60 changes aimed at enhancing flexibility, improving environmental protection, and clarifying compliance requirements for hazardous waste generators. The MassDEP representative outlined several significant components of the GIR that are relevant to Massachusetts' regulatory framework.

One of the primary changes discussed was the allowance for Very Small Quantity Generators (VSGs) to consolidate hazardous waste under the control of the same company, which is expected to streamline waste management processes. Additionally, the rule introduces provisions for episodic generation, enabling generators to maintain their lower status even if they temporarily exceed their waste generation limits, provided they meet specific conditions.

The meeting also highlighted updates to emergency preparedness regulations, which require Small Quantity Generators (SQGs) and Large Quantity Generators (LQGs) to coordinate with local emergency planning officials. This includes submitting quick reference guides that summarize key information for local responders when developing or updating contingency plans.

Further proposed changes include a requirement for periodic re-notification of Small Quantity Generators every four years, as opposed to the current one-time notification. The regulations will also enhance labeling and marking requirements for hazardous waste containers to ensure clearer hazard communication.

MassDEP tentatively proposed to adopt several specific provisions from the GIR, including improved labeling for hazardous waste containers, notification requirements for LQGs planning to close their facilities, and the necessity for SQGs to re-notify every four years. The agency also plans to implement the requirement for generators to report all hazardous waste generated in a calendar year, not just during the months they qualify as LQGs.

The meeting concluded with a commitment to further refine these proposals and engage with stakeholders to ensure effective implementation of the updated hazardous waste regulations. The next steps will involve public feedback and additional discussions to finalize the adoption of these critical regulatory changes.