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EPA Extension For RCRA HSM Requirements

The Environmental Protection Agency (EPA) has recently proposed an extension of the information collection request (ICR) Revisions to the RCRA Definition of Solid Waste (EPA ICR No. 2310.04, OMB Control No. 2050–0202) that is currently approved through April 30, 2018. This ICR requires records be kept for hazardous waste generators, recyclers, and contractors for the recycling of hazardous secondary materials.

This record-keeping requirement comes from EPA’s final rule on the definition of solid waste which better-defined hazardous secondary materials recycling standards and its exclusions ( The requirements such as the record-keeping item above are intended to create better management of safe and responsible hazardous secondary materials recycling as there has been previous evidence of mismanagement by recycling companies. These regulations prevent recycling facilities from illegally disposing of hazardous materials.

The ICR extension would include shipping records, financial assurance documents, training, labeling of storage containers, and emergency preparedness and response requirements.

The EPA is still accepting comments on this ICR extension until April 27, 2018 under Docket ID No. EPA-HQ-OLEM-2018-0013 at, by e-mail to or by mail.

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