Changes in Hazardous Waste Management- The Generator Improvement Rule
Changes in Hazardous Waste Management- The Generator Improvement Rule

If you haven’t heard by now, you should know that the EPA published its Generator Improvement Rule (GIR) in 2016. It is an update to the organization’s Resource Conservation and Recovery Act (RCRA), a set of regulations regarding chemical waste management, which was passed back in 1976. The original regulations were mainly aimed at large industries, and making the rules apply in hospitals and laboratories was no easy task. In 2018 many states adopted the GIR, and that changed the way hospitals located there will handle hazardous waste. In 2019, many more states will adopt the rule, so you need to be aware of the updates.

The first notable set of changes involves chemical waste labeling. Hazardous waste containers stored in a Satellite Accumulation Area or Central Accumulation Area have always needed some form of label, but the GIR has increased the labeling requirements for such containers. Every receptacle used to store chemical waste must now be labeled with the words “Hazardous Waste.” There must be a description of the waste (such as “alcohol waste” or “stainer waste,” etc.), and there must be some form of hazard warning present on the label. The type of warning a label must indicate is not specified in the regulations, so labs may choose their own methods of displaying the information. Warning pictograms can be used, or NFPA or HMIS warning conventions can also be used to convey the particular hazard(s) of the contents. Make sure staff is trained on whichever hazard warning convention is used.

The implementation of the GIR ruling can give healthcare organizations more flexibility with waste movement that can save money. In the past, the EPA would not allow chemical waste to be transported off of the grounds of the hospital unless it was moved by a licensed transporter. Contracted waste haulers remove hazardous waste from a facility, and they can charge the organization fees based on the number of visits, the waste volumes, and the time spent in the facility. The GIR revisions permit a site designated as a Very Small Quantity Generator to move chemical waste to another location designated as a Large Quantity Generator. The LQG site must be under the control or ownership of the same organization as the VSQG site. That hazardous waste can be moved by a representative of the company rather than a contracted hauler. If a hospital organization is able to reduce the number of pick-ups by a contracted waste transporter, overall expenses will be reduced.

A third benefit of the implementation of GIR standards is the ability for some labs or hospitals to generate more than what is allowed by the facility’s EPA generator status. Many hospitals are designated as a Small Quantity Generator, meaning they may create no more than 2200 lbs of hazardous waste each month. In the past, if that volume was exceeded by the site, the hospital would need to report to the EPA and re-designate itself as a Large Quantity Generator for the rest of that calendar year. That re-designation costs money and time. Under the GIR, VSQG and SQG sites may go over their allotted amount of waste two times per year- once as a planned event and once unplanned. This new flexibility allows sites to perform functions (like cleaning out a stock room of old chemicals, for example) without having to report a status change to the EPA.

In 2018 eleven different U.S. states adopted the Generator Improvement Rule to make it easier for healthcare facilities to comply with complicated chemical waste regulations. This year twenty-four more states will adopt the updated ruling (go to to see where your state is in the rule adoption process). No matter where you are in the rule adoption process, be sure you understand the regulations, and train staff so they are ready to comply with the updated standards. Managing hazardous waste is a complicated undertaking, but it must be done correctly in order to keep those who work with chemical waste safe each and every day.

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