According to EPA, the rule is designed to provide for greater flexibility to generators in managing their hazardous waste. In particular, the rule clarifies the definitions of small quantity generators (“SQGs”) and very small quantity generators (“VSQGs”) (previously known as conditionally exempt small quantity generators), and allows them to maintain their small generator status despite episodic generation of higher quantities of waste.
Baker Botts environmental lawyers Bart Seitz and Martha Thomsen are available to comment.
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