The Environmental Protection Agency (EPA) defines an episodic event as an activity that does not normally occur during a generator’s operations. The event causes a hazardous waste generator to exceed the upper limit of its normal generator category for that month.
This often affects Small Quantity Generators (SQGs) or Very Small Quantity Generators (VSQGs) negatively, as one planned episodic event such as tank clean-outs or regular maintenance combined with one unplanned episodic event such as an accidental spill or natural disaster will likely put that generator in excess of their monthly limits.
Some Facilities Alter Their Generator Status on Purpose
By operating in ordinance with the monthly limits of the group above your facility’s waste generator status, it’s easy to ensure that your facility is always compliant with stringent regulations and training requirements for your employees.
This strategy is particularly useful if your facility fluctuates between multiple generator statuses, as a series of unplanned events can subject your facility to hefty fines for going over the designated amount of waste. We always recommend a conservative strategy.
Episodic Events can be Planned or Unplanned
Neither planned and unplanned episodic events are a regular part of business operations. While these events are a necessary part of business operations, they are neither regularly recurring or a part of the facility’s monthly waste generation limit.
Planned Episodic Events
The EPA must be notified of planned events 30 days before the event. Waste must be removed from the site within 60 days of the event, and records must be maintained for up to three years after the event has occurred.
Potential Planned Episodic Events:
- Yearly maintenance on equipment
- Special or atypical projects
- Removal of excess inventory
Unplanned Episodic Events
The EPA must be notified of an unplanned event within 72 hours of the occurrence. Waste must be removed from the site within 60 days of the event, and records must be maintained for up to three years after the event has occurred.
Potential Unplanned Episodic Events:
- Natural disasters
- Accidental spills
- Product recalls
Facilities can Petition for an Additional Episodic Event
A second episodic event can be applied for in the event that the first event was planned and the second event was both unplanned and notified to the EPA within 72 hours of occurrence.
Petitions Filed Unnecessarily Can be Canceled
The EPA must be notified of an unplanned event within 72 hours of the event. The EPA recognizes, however, that VSQGs and SQGs might not know to what extent the waste is hazardous until the end of the event. We advise treating the event conservatively. Overreporting is better in the long run than underreporting.
According to the EPA, all materials suspected of being hazardous waste “must label the waste with the words ‘Episodic Hazardous Waste,’ with a word, placard or pictogram that identifies what the hazards are that the waste poses, and with the start date of the episodic event.”
Failure to Comply Will Affect Your Status
If the quantity of hazardous waste limit is exceeded, or a VSQG, SQG, or LQG doesn’t comply with one of the handling conditions, then that facility will be considered to be operating without a permit or without interim status. That facility will be treated as a non-exempt storage facility.
An operator of an existing treatment, storage, or disposal facility can still legally operate in interim status while waiting on their permit and decision from the EPA, but VSQG or SQG facilities must apply for the next-highest exemption level in order to continue to conduct business.
The Rules Were Defined Precisely Over Time
The 1976 Resource Conservation and Recovery Act is still the principal federal law governing hazardous waste. The first-ever regulatory program for hazardous waste generation came into effect in 1980.
Since the program’s inception, the EPA has maintained enough flexibility and certainty to allow businesses to operate successfully while also protecting the environment. Since 2015, the clear-cut set of rules and regulations surrounding episodic events are listed on the EPA’s website.
HWH Environmental
When hazardous waste is routinely generated and stored at your company, regardless of your generator status, it is crucial to work with a partner that is experienced, well-trained and maintains top safety practices in removing hazardous waste products. This is where the team at HWH Environmental can make all the difference. Our responsive customer service team is here to help you answer any questions. Get in touch today.
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