MOST COMMON RCRA VIOLATIONS
IN HEALTHCARE
- Hazardous waste determinations
- Unmarked/unlabeled containers
Note: Don’t forget contractors and consultants
RCRA Training Courses
RCRA Waste Management Compliance and Training
RCRA, or the Resource Conservation and Recovery Act, authorizes EPA to regulate the waste management and disposal activities of industrial and municipal waste generators; treatment, storage, and disposal facilities (TSDFs); and waste transporters. Thousands of individuals and facilities, from the local dry cleaner to hazardous waste incinerators, are regulated by RCRA. It should not be confused with CERCLA (Comprehensive Environmental Response, Compensation, and Liability Act), often referred to as Superfund, which among other things regulates the accidental release and cleanup of hazardous wastes.
RCRA Regulates Cradle to Grave
Under Subtitle C of RCRA, all hazardous waste and solid waste must be managed from its generation to final disposal, known as “cradle to grave.” The waste is tracked with a hazardous waste manifest—a shipping document that travels with hazardous waste from the point of generation, through transportation, to the final TSDF. This tracking form is at the heart of the EPA hazardous waste management system.
RCRA also authorizes states to develop and enforce their own waste management programs once they are approved by EPA.
Other RCRA Regulations
Subtitle D of RCRA governs the management and disposal of solid waste, especially the design and operation of municipal solid waste landfills and other solid waste disposal facilities. It regulates the management of household garbage and nonhazardous industrial solid waste.
Subtitle I of RCRA regulates the storage of petroleum products and hazardous substances in underground storage tanks.
RCRA Penalties Can Be Severe!
If you violate RCRA hazardous waste rules, you can be fined $37,500 per day per violation. If you knowingly break RCRA regulations, you can be fined $50,000 per day per violation and be sentenced to 5 years in prison. States that run their own RCRA programs can impose their own penalties in addition to the federal penalties
Guidance for RCRA from the Fed Center
2005 RCRA Data Call (PDF 80.67 KB)
Section 6002 of the Resource Conservation and Recovery Act (RCRA) requires the Office of Federal Procurement Policy (OFPP) to report to Congress every two years on the actions taken by Federal agencies to implement the statute. OFPP and OFEE have developed the attached survey to collect the information required to meet the reporting required by RCRA and E.O. 13101.
Hazardous Waste Generator Regulations: A User-Friendly Reference Document
This document, dated 2 May 2007, includes hyper-link references to frequently asked questions, letters, memoranda, and guidance concerning hazardous waste.
RCRA Call Center Reports
This is a compilation of questions to the RCRA Call Center and the responses to the questions for the years 1991 – 2004.
RCRA Online
This is a database is designed to enable users to locate documents, including publications and other outreach materials, that cover a wide range of RCRA issues and topics.
Resource Conservation and Recovery Act (RCRA) Enforcement Policy and Guidance
Maintained by EPA's RCRA Enforcement Division, this site contains the policy, guidance, and other documents that are currently used in RCRA Enforcement and the RCRA Enforcement Policy and Guidance Archives with the documents that are no longer used. Topics include, but are not limited to: groundwater, inspections, permitting, and USTs.
Waste Frequent Questions
This site consolidates the answers to frequent questions about RCRA and provides a forum for the use to ask a question themselves.
Guidance for RCRA, Subtitle C
Determining Equivalency of State RCRA Hazardous Waste Programs
This September 7, 2005 memorandum from the head of the EPA's Office of Solid Waste to agency regional directors "reaffirms EPA's commitment to employing appropriate flexibility in the review of state programs" authorized under RCRA. The memorandum is a response to a workgroup established in April 2003 to examine potential improvements to the process by which EPA determines whether state hazardous waste programs are equivalent to the federal program.
Facilities and Enforcement Activities related to the Resource Conservation and Recovery Act (RCRA Subtitle C)
This page provides information about facilities regulated under the RCRA, Subtitle C (i.e. hazardous waste) and corresponding information about EPA, state and local inspections, violations, and enforcement. This page also provide links to numerous other EPA websites with RCRA, Subtitle C information.
Hazardous Waste Listings: A User Friendly Document
This document describes the Environmental Protection Agency's (EPA's) hazardous waste listing regulations under the authority of the Resource Conservation and Recovery Act (RCRA) Subtitle C and includes hyperlinks to information that EPA has generated over the years to explain the listing regulations. The objective of this document is to consolidate and streamline the information on listing regulations to help Environmental Protection Agency (EPA) staff, state staff, industrial facilities, and the public understand hazardous waste listing regulations.
National Treatability Variance From the Land Disposal Restriction (LDR) Standards for Waste Batteries
This variance, effective November 2002, applies specifically to radioactively contaminated cadmium-, mercury-, and silver-containing waste batteries .The Regulatory Bulletin discusses the LDR treatment standard established for these mixed waste batteries, the DOE petition that requested the treatability variance, the rationale for granting the variance, and implementation at the State level.
State Authorization Tracking System (StATS)
This is an information management system designed to document the progress of each state and territory in establishing and maintaining RCRA-authorized hazardous waste management programs.
Guidance for RCRA, Subtitle I
40 CFR 280, Q & A from the UST Technical Compendium (DOC 48.13 KB)
Questions and answers for some of the most common concerns related to 40 CFR 280.
EPA Guidance for Underground Storage Tank Compliance Act Data Reporting (PDF 135.07 KB)
EPA OUST/FFEO memo, dated 01 Feb 2006, providing guidance and assistance to Federal Agencies on their data reporting requirements of the Underground Storage Tank Compliance Act of 2005.
EPA Memo - OUST To Post Federal Agency UST Compliance Reports (PDF 361.61 KB)
EPA memorandum dated October 17, 2006, by Cliff L. Rothenstein (Director), Office of Underground Storage Tanks, announcing to Federal Facility Environmental Executives that agency underground storage tank compliance reports will be posted on the EPA website and that specific UST information will be provided to the EPA Regions and States.
EPA Memorandum - Implementation of the UST Compliance Act of 2005 (PDF 463.72 KB)
In Section 1528 of the Act all departments and federal agencies that own, operate, or manage one or more federally regulated USTs to report the compliance status of their USTs to EPA and Congress by August 8, 2006. In order to facilitate this reporting, the EPA is requesting that every Federal Agency Environmental Executive provide the name of one representative per department or agency with who the EPA can coordinate. The memorandum, dated 17 October 2005, was signed by the Director of the Office of Underground Storage Tanks (OUST), Office of Solid Waste and Emergency Response (OSWER) and the Director of the Federal Facilities Enforcement Office (FFEO), Office of Enforcement and Compliance Assurance (OECA).
EPA Memorandum - Issuance of Secondary Containment Grant Guidelines for Underground Storage Tanks Programs (PDF 741.35 KB)
November 15, 2006 memorandum announcing issuance of final document that implements a key provision of the underground storage tank amendments of the Energy Policy Act of 2005; the secondary containment grant guidelines.
Grant Guidelines to States for the Implementation of UST Provisions Under the Energy Policy Act of 2005
There are multiple grant guidelines issued by the EPA for the management and inspection of USTs, including the following titles: Inspection (24 April 2007); State Compliance Reports On Government Underground Storage Tanks (24 April 2007); Public Record (22 January 2007); Financial Responsibility And Installer Certification (22 January 2007); Secondary Containment (15 November 2006); Delivery Prohibition (7 August 2006); Tribal Strategy (7 August 2006). States will not receive RCRA Subtitle I funding unless these guidelines are met.
RCRA Frequently Asked Questions (FAQs)
A database that will allow any user to search for RCRA information from a comprehensive set of FAQs or submit their own question or comment on a variety of RCRA issues and topics.
RCRA OnLine
This database is designed to enable users to locate documents, including publications, OSW memos, and other outreach materials, that cover a wide range of RCRA issues and topics.
Resource Conservation and Recovery Act (RCRA) Enforcement Policy and Guidance
Maintained by EPA's RCRA Enforcement Division, this site contains the policy, guidance, and other documents that are currently used in RCRA Enforcement and the RCRA Enforcement Policy and Guidance Archives with the documents that are no longer used. Topics include, but are not limited to: groundwater, inspections, permitting, and USTs.
State RCRA Contacts
Links to the state POCs with RCRA expertise. Particularly valuable for states with RCRA primacy.
Guidance for the Safe Drinking Water Act (SDWA)
Arsenic Small Entity Compliance Guide
This guide is designed to help systems understand and achieve compliance with the Arsenic rule. The guide provides sample worksheets to help systems organize data, and provides guidance for small systems on their selection of appropriate compliance options. This is EPA document EPA 816-R-02-008A.
Arsenic Treatment Technology Case Studies
EPA is highlighting eleven Arsenic Rule Compliance Success Stories, a series of case studies highlighting public water system experiences in meeting the revised drinking water standard. These community and non-residential water systems utilized innovative or lower cost approaches to meeting the revised 10 ppb maximum contaminant level for arsenic.
Complying with the Long Term 2 and Stage 2 DBP Rules
Developed by EPA, this guidance manual discusses the issues that systems will face as they evaluate and implement changes necessary to comply with the Stage 2 Disinfectants and Disinfection Byproduct Rule and the Long Term 2 Enhanced Surface Water Treatment Rule, while still being required to comply with earlier rules such as the Total Coliform Rule and Lead and Copper Rule. This manual builds on a similar manual developed for the Stage 1 DBP rule, incorporating new research and case studies, and is presented in a more user-friendly manner. EPA developed this guidance manual to provide systems and states with information on operational and capital changes and approaches to enable systems to evaluate different compliance strategies and technologies.
Complying With the Stage 1 Disinfectants and Disinfection Byproducts Rule: Basic Guide
This guide, EPA 816-B-05-004, applies to small systems adding any chemical disinfectant and was published March 2006. The intent of the guide is to aid systems in complying with the Stage 1 Disinfectants and Disinfection Byproducts Rule (Stage 1DBPR) published on December 16, 1998 under the Safe Drinking Water Act (SDWA).
Complying With the Stage 1 Disinfectants and Disinfection Byproducts Rule: Supplement A
This supplement, EPA 816-B-05-005, applies to small systems adding chlorine dioxide or ozone and was published March 2006. This document supplements EPA 816-B-05-004. This supplement is intended to aid you in complying with the Stage 1 Disinfectants and Disinfection Byproducts Rule (Stage 1 DBPR) published on December 16, 1998, under the Safe Drinking Water Act (SDWA).
Complying With the Stage 1 Disinfectants and Disinfection Byproducts Rule: Supplement B
This supplement, EPA 816-B-05-006, applies to small subpart H systems using conventional filtration treatment and was published March 2006. This document supplements EPA 816-B-05-004. This supplement is intended to aid you in complying with the Stage 1 Disinfectants and Disinfection Byproducts Rule (Stage 1 DBPR) published on December 16, 1998, under the Safe Drinking Water Act (SDWA).
Consecutive Systems Guidance Manual for the Stage 2 DBPR
This EPA Manual, Number 815-R-09-017 March 2010, discusses requirements for consecutive systems (public water systems that receive fully treated water from other public water systems) to comply with Stage 2 DBPR monitoring and MCL requirements. EPA has developed this guidance manual to provide information on operational and capital changes and strategies that will enable consecutive systems to comply with the Stage 2 DBPR requirements.
EPA’s Arsenic Virtual Trade Show
An EPA learning portal designed to help water systems, especially small water systems, comply with EPA's Arsenic Rule which is effective 23 January 2006. The portal enables the user to work through a decision tree and educate themselves about treatment options before committing to any given treatment.
FY 07 National Water Program Guidance
The Guidance describes priorities for the National Water Program for FY 2007, outlines the strategy for accomplishing specific environmental goals in the coming year, and identifies measures of progress to be used to assess progress. EPA Regions will use the Guidance in working with States and Tribes to develop workplans and related materials and will use "targets" for measures in the Guidance as a point of reference for making "commitments" under the measures.
FY06 National Water Program Guidance
This document details the steps to be taken in FY06 towards meeting the EPA water program’s strategic plan.
Memo Clarifying EPA's Position on the Use of Daily Time Increment When Establishing Total Maximum Daily Loads for Pollutants (DOC 44.54 KB)
This memorandum, dated 15 November 2006, clarifies EPA's expectations concerning the appropriate time increment used to express "total maximum daily loads" (TMDLs).
National Water Program Strategic Plan 2004 – 2008
This document details the steps to be taken in FY06 towards meeting the EPA water program’s strategic plan.
Talking to your Customers about Chronic Contaminants in Drinking Water
Developed by EPA, this is a best practices guide that helps public water systems communicate with the public about drinking water risks. Chronic contaminants are those that can cause health effects after continuous long-term exposure. This fact sheet discusses the importance of communicating with the public about chronic contaminants - both regulated and unregulated - and describe effective strategies for getting the message out.