Cal CUPA Guidance on Generator Improvements Rule

Update 07/01/2024

California DTSC released resources to help hazardous waste generators meet the new requirement for a “Quick Reference Guide” or “QRG” as part of the site contingency plan.

Generators can now find a page of instructions for creating a quick reference guide and a template to use to create a QRG on DTSC's website: 

California Quick Reference Guide Instructions
California Quick Reference Guide Template
California Quick Reference Guide Extra Template Pages

The hazardous waste Generator Improvements Rule significantly revised and reorganized California's hazardous waste regulations. New and revised requirements took effect July 1, 2024.

Cal CUPA Guidance on Generator Improvements Rule 

Posted 06/21/24
To help hazardous waste generators in California achieve compliance with new and revised regulations from the Generator Improvements Rule, California DTSC and the Certified Unified Program Agencies (CUPA) plan to release guidance before July 1, 2024.

In June, state regulators announced plans to release two resources to assist the regulated community with compliance following substantial updates to the state’s hazardous waste regulations finalized in May 2024. 

CUPA Resources: Generator Improvements Rule

As announced in the Unified Program Newsletter, by July 1, CUPA will share: 

•    A “comprehensive Frequently Asked Questions (FAQ) webpage;” and 
•    A Quick Reference Guide (QRG) template for large quantity generators. 

Both resources will be posted to  DTSC’s Generator Improvements Rule webpage.

The template for a Quick Reference Guide (QRG)—a new mandatory element of the contingency plan for large quantity generators—will be available on the California Environmental Reporting System (CERS) website. 

What's In the Generator Improvements Rule?

Areas of the California State hazardous waste management laws and regulations affected by the Generator Improvements Rule include: 

• Generator site notifications to DTSC. 
• Contingency planning and emergency preparedness.
• Container markings/labels during accumulation and pre-transportation.
• Updates for storing ignitable or reactive wastes at LQG sites.
• Managing incompatible wastes in satellite areas. 

The Generator Improvements Rule also re-structures the standards for generators in California to align them with re-arranged Federal RCRA regulations, moving the rules mainly to new sections of 22 CCR Part 66262.

California Generator Improvements Rule: Resources from Lion

Generator Improvements Rule Cheat Sheet. A free, one-page cheat sheet available at Lion.com/CA provides a concise summary of new, more stringent provisions for generators added to California's Title 22 hazardous waste regulations. It also includes a "finding aid" that directs generators to newly re-located sections of the state regulations. 

Online course updates. A new tutorial now featured in four Lion online courses highlights key updates to California's State hazardous waste regulations in effect as of July 1, 2024. The Tutorial summarizes new and revised requirements in the "Generator Improvements Rule." 

Member Bulletin. Available to current Lion Members, this Lion Member Bulletin outlines key requirements and deadlines in the Generator Improvements Rule finalized in California. 

California Hazardous Waste "Generator Improvements" Training

Attend an upcoming California Hazardous Waste Management Workshop for clear, comprehensive training on these rule updates and how they impact you. You will leave more prepared to make the changes your site needs to stay in compliance, with resources and ongoing support to guide your decisions.