Michigan’s New Hazardous Waste Rules Now In Place

Amendments to the generator hazardous waste rules were officially filed with the Michigan Department of State in late July and these new hazardous waste rules became effective on August 3, 2020. So what are these changes and how do they affect you?

These revisions address the following subject areas:

• Generator improvements rule (GIR) (81 Federal Register (FR) 85732, November 28, 2016)

• Exports/imports (81 FR 85696, November 28, 2016 and 82 FR 60894, December 26, 2017)

• E-manifesting (83 FR 420, January 3, 2018)

• Definition of solid waste 2018 court vacatur (83 Federal Register (FR) 24664, May 30, 2018)

• Designation of aerosol cans as universal waste (84 FR 67202, December 9, 2019)

• Elimination of 52 state-only hazardous waste listings

Specifically, the GIR is noted. The GIR significantly restructured the generator rules to make it easier to determine the requirements that apply to each type of generator and include provisions for episodic events and large quantity generator consolidation of certain wastes. These rules were originally published in by the USEPA in the Federal Register in 2016 and adopted by EGLE this year.

There are several objectives to these GIR revisions. They include:

• Reorganizing the hazardous waste generator regulations to make them more user-friendly and thus improve their usability by the regulated community;

• Providing a better understanding of how the RCRA hazardous waste generator regulatory program works;

• Addressing gaps in the existing regulations to strengthen environmental protection;

• Allowing greater flexibility for hazardous waste generators to manage their hazardous waste in a cost-effective and protective manner; and

• Making technical corrections and conforming changes to address inadvertent errors and remove obsolete references to programs that no longer exist.

The designation of aerosol cans as universal waste is also notable as it has implications for most generators. Specifically, USEPA and EGLE have now added hazardous waste aerosol cans to the universal waste program. This change will benefit establishments generating and managing hazardous waste aerosol cans by providing a clear, protective system for managing discarded aerosol cans. The streamlined universal waste regulations are expected to promote the collection and recycling of these cans.

CFR has been helping generators manage their hazardous waste for over 30 years. Contact CFR Environmental to learn more about how we can assist with your environmental compliance needs.