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2018 New Hazardous Waste Rules

The U.S. Environmental Protection Agency (EPA) is expected to finalize two new hazardous waste regulations in 2018:

1. Management Standards for Hazardous Waste Pharmaceuticals

This rule was originally proposed in September 2015, and its main purpose is to provide regulatory relief by enacting specific regulations for the management of hazardous waste pharmaceuticals by health care facilities. These facilities have found it difficult to comply with the Resource Conservation and Recovery Act (RCRA) Subtitle C hazardous waste regulations due to a lack of knowledge of RCRA waste regulations and difficulties in determining which wastes are hazardous as pharmaceuticals typically contain a long list of chemicals within their formula. This new management standard will allow generators to exclude some pharmaceuticals from their monthly generation limits thus allowing the facilities to potentially become a lower class of generator. In addition to this major update, the proposed rule will also reduce the amount of pharmaceuticals that enter U.S. waterways by banning healthcare facilities from flushing hazardous waste pharmaceuticals down any drains or toilets.

2. Electronic Hazardous Waste Manifest (e-manifest)

The final rule was signed on December 20, 2017 and the EPA is expected to launch the e-manifest system in June 2018. Please see for more information on the final rule. Baron will provide additional details on this new system once they become available.

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