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MDEQ’s Regulatory Revisions to Conform to New Federal RCRA Requirements

Michigan is updating its hazardous waste regulations (the “Part 111 rules”) to conform to many recent federal updates to Resource Conservation and Recovery Act (RCRA) regulations regarding the Hazardous Waste Generator Improvements Rule, E-Manifest, Definition of Solid Waste.  The state hopes to have these regulatory changes in place before the end of 2018. Among the changes at the state level, the Michigan Department of Environmental Quality (MDEQ) is revising regulations that will update generator requirements, include updated requirements for exporting and importing hazardous waste, incorporate the electronic manifesting requirements and will add aerosol cans as a universal waste.  The majority of these revisions will become effective and enforceable by MDEQ once the rules are adopted.  However, the E-Manifest requirements will take effect nationwide on June 30, 2018.

This presentation explains Michigan’s proposal for these changes and provides additional background information on the underlying federal changes including helpful updates on the status of the adoption of these major programmatic updates in other states.


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