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August 2020
S&R of the Sun
Included in this newsletter are thirteen articles all related to one subpart of the regulations: Preparedness, Prevention, and Emergency Response for a Large Quantity Generator of Hazardous Waste.

Preparedness, Prevention, and Emergency Response for a Large Quantity Generator of Hazardous Waste
A large quantity generator of hazardous waste (LQG) is required to have certain equipment and procedures in place to prevent emergencies from happening and to respond to them when they do. Requirements include – but are not limited to – a documented contingency plan and identified emergency coordinators with specified response actions. If that wasn’t enough, these long-standing regulations were changed by the Generator Improvements Rule. If you are a LQG in a state that has, or will, adopt the Generator Improvements Rule, you must read this series of articles to discover your new compliance requirements. Below is a summary of each section with a link to more in-depth identification and explanation. Or, click here to see all of the preparedness, prevention, and emergency procedures for large quantity generator of hazardous waste.
40 CFR 262.250 Applicability
A small change in language, but a big change in the applicability of these regulations. Be sure to read and understand!
Fire Fighting Gear
40 CFR 262.251 Maintenance and Operation
No big changes. Skip this one if you don't have time now. But be sure to come back later for a full understanding. Learn more.
40 CFR 262.252 Required Equipment
No change in the required equipment but changes to the applicable areas of the LQG where this equipment must be located. Read this!
40 CFR 262.253 Testing and Maintenance of Equipment
No change from prior to the Generator Improvements Rule. A quick read and pretty simple to comply.
40 CFR 262.254 Access to Emergency Communication
Read this! The addition of a few words “direct or unimpeded” emphasizes USEPA’s new requirement for “immediate access” to emergency communication devices.
Telephone Operator
262.255 Required Aisle Space
No change of any significance. But, are you aware of the required aisle space you must maintain to any area of your facility? If not, read on…
40 CFR 262.256 Arrangements with Local Authorities
Important and revised by the Generator Improvements Rule. You must read this!
40 CFR 262.260 The Contingency Plan
40 CFR 262.261 Content of Contingency Plan
Significant changes from the Generator Improvements Rule. Be sure to read this!
40 CFR 262 Copies of Contingency Plan
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Big Change! You must now submit a Quick Reference Guide with your new or updated Contingency Plan. Learn more.
40 CFR 262.263 Amendment of Contingency Plan
No change by the Generator Improvements Rule but still important. Be sure to read this to know when changes to your Contingency Plan are required.
40 CFR 262.264 Emergency Coordinator
No significant changes by the Generator Improvements Rule but a lot of critical information about who can be an Emergency Coordinator at a LQG. Be sure to check this out!
40 CFR 262.265 Emergency Procedures
Minor changes by the Generator Improvements Rule but a significant responsibility for any LQG. What are the required emergency procedures in the event of a hazardous waste emergency? Read this to learn.
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2020 Upcoming Webinars

USDOT HazMat Employee September 14th
USEPA Hazardous Waste (RCRA) September 21st


USDOT HazMat Employee October 5th
USEPA Hazardous Waste (RCRA) October 19th

Register now by clicking on the date above.

Or, contact me to make arrangements for a site-specific webinar scheduled at your convenience.
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Daniels Training Services
A different kind of training
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I provide training and consulting services to equip your team – whether it’s just you or a group of employees – to safely ship, receive, transport or dispose of hazardous materials and waste.