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Resource Conservation and Recovery Act

The definitive guide to RCRA compliance. Understand the federal framework governing the proper management of hazardous and non-hazardous solid waste from cradle to grave.

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What is RCRA?

The Resource Conservation and Recovery Act (RCRA) is the principal federal law in the United States governing the disposal of solid waste and hazardous waste. Passed in 1976, it grants the Environmental Protection Agency (EPA) the authority to control hazardous waste from "cradle-to-grave."

Federal Framework

Establishes the framework for a national system of solid waste control, ensuring environmental protection while promoting resource recovery.

Cradle-to-Grave

Comprehensive tracking of hazardous materials from their initial generation, through transportation, to their final disposal or treatment.

EPA Enforcement

Provides the EPA with enforcement authority, including civil and criminal penalties, to ensure compliance with hazardous waste regulations.

EPA compliance manual

Subtitle C vs Subtitle D

RCRA is divided into specific "subtitles" that govern different types of waste. The two most critical for environmental compliance are Subtitle C and Subtitle D.

Subtitle C: Hazardous Waste

Establishes a federal program to manage hazardous wastes from cradle to grave. This ensures that hazardous waste is managed safely from the moment it is generated to its final disposal.

Subtitle D: Non-Hazardous Waste

Focuses on state and local governments as the primary planning, regulating, and implementing entities for the management of non-hazardous solid waste, such as household garbage.

Generator Categories

RCRA regulations apply differently based on the volume of hazardous waste a facility produces in a calendar month. The EPA establishes three distinct generator categories.

VSQG

Very Small Quantity Generator

  • Generates 100 kilograms or less per month
  • Must identify all hazardous waste generated
  • Cannot accumulate more than 1,000 kg at any time
SQG

Small Quantity Generator

  • Generates between 100 kg and 1,000 kg per month
  • May accumulate waste on-site for 180 days without a permit
  • Requires EPA Identification Number
LQG

Large Quantity Generator

  • Generates 1,000 kilograms or more per month
  • May accumulate waste on-site for 90 days
  • Subject to full RCRA Subtitle C regulations
Perfectly aligned steel drums for hazardous waste

Hazardous Waste Characteristics

Under RCRA, a waste is considered hazardous if it exhibits one or more of four specific characteristics. Identifying these characteristics is the critical first step in compliance.

Ignitability

Can create fires under certain conditions or are spontaneously combustible.

Corrosivity

Acids or bases that are capable of corroding metal containers.

Reactivity

Unstable under normal conditions. Can cause explosions or toxic fumes.

Toxicity

Harmful or fatal when ingested or absorbed, causing ground water pollution.

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Frequently Asked Questions

Comprehensive answers to common RCRA inquiries.