Generator Improv. Rule
EPA Form 8700-12
Reverse Distribution
HW Pharmaceuticals Rule
HW DETERMINATIONS
100

TRUE OR FALSE, THE LAST REMAINING REQUIREMENT OF THE GENERATOR IMPROVEMENTS RULE DOES NOT TAKE EFFECT UNTIL 2021

TRUE  - that is the SQG re-notification date

100

TRUE OR FALSE, A HAZ WASTE GENERATOR IS REQUIRED TO SUBMIT A REVISED FORM 8700-12 WHEN THEY HAVE A NEW SOLID WASTE STREAM

FALSE, A HAZ WASTE GENERATOR IS REQUIRED TO SUBMIT A REVISED FORM 8700-12 WHEN THEY HAVE A NEW HAZARDOUS WASTE STREAM

100

TRUE OR FALSE, A REVERSE DISTRIBUTOR SHOULD DETERMINE MANUFACTURER CREDIT AT THE POINT OF GENERATION

FALSE, Determination of credit occurs at the RD facility

100

TRUE OR FALSE, A MANUFACTURER OF PHARMACEUTICALS IS A HEALTHCARE FACILITY

FALSE, A MANUFACTURER OF PHARMACEUTICALS IS SPECIFICALLY EXCLUDED FROM THE DEFINITION OF A HEALTHCARE FACILITY

100

TRUE OR FALSE, A HAZ WASTE DETERMINATION MUST BE MADE AS SOON AS A SOLID WASTE EXITS A STORAGE TANK?

FALSE, A HAZ WASTE DETERMINATION MUST BE MADE AS SOON AS A SOLID WASTE IS GENERATED WHICH OCCURS PRIOR TO STORAGE

200

IS THERE ANYTHING WRONG WITH THIS SENTENCE? IF SO, WHAT?

AN EPISODIC GENERATOR CAN RECEIVE ONE THIRTY DAY EXTENSTION TO THE 60 DAY EPISODIC WASTE MANAGEMENT PERIOD

Yes, an episodic generator cannot get any extensions to the 60 days

200

IS THERE ANYTHING WRONG WITH THIS SENTENCE? IF SO, WHAT?

A FACILITY CAN OPT INTO SUBPART K AND SUBPART P AT THE SAME TIME ON THE 8700-12 FORM

No, the sentence is correct

200

IS THERE ANYTHING WRONG WITH THIS SENTENCE? IF SO, WHAT?

A REVERSE DISTRIBUTOR MUST ESTABLISH A SPECIFIC ACCUMULATION AREA FOR POTENTIALLY CREDITABLE HW PHARMACEUTICALS

Yes, an RD can store HW Pharms in an existing HW accumulation area, or can store with evaluated HW pharms – no separate are is needed

200

IS THERE ANYTHING WRONG WITH THIS SENTENCE? IF SO, WHAT?

A VSQG THAT OPTS INTO SUBPART B MUST REMAIN A SUBPART P FACILITY FOR AT LEASTS ONE YEAR

Yes, there is no minimum time frame. However, a VSQG that opted in cannot start managing Subpart P waste as HW until it has opted out.

200

IS THERE ANYTHING WRONG WITH THIS SENTENCE? IF SO, WHAT?

THE TEST FOR REACTIVE HAZARDOUS WASTE MUST BE PERFORMED BY A VELAP LABORATORY

Yes, there is no test for reactivity

300

TRUE OR FALSE,

A LQG MUST NOTIFY WITHIN 30 DAYS OF AN UNPLANNED EPISODIC EVENT?

FALSE,

A LQG MUST NOTIFY WITHIN 3 DAYS OF AN UNPLANNED EPISODIC EVENT by phone or email and follow up in writing – 30 days prior is for planned

300

TRUE OR FALSE,

A VSQG MUST NOTIFY IF IT CHOOSES TO SEND ITS POTENTIALLT CREDITABLE HW PHARMACEUTICALS TO AN SQG UNDER THE SAME PERSON

FALSE,

A VSQG cannot send its HW TO AN SQG UNDER THE SAME PERSON, it must be an LQG

300

TRUE OR FALSE,

REVERSE DISTRIBUTORS MUST SEND EVALUATED HW PHARMACEUTICALS TO A TSD WITHIN 90 DAYS

FALSE,

REVERSE DISTRIBUTORS have one year to send EVALUATED HW PHARMACEUTICALS TO A TSD

300

TRUE OR FALSE,

SUBPART O WAS CREATED IMMEDIATELY BEFORE SUBPART P TO ESTABLISH DESIGN REQUIREMENTS FOR HEALTHCARE FACILITIES

FALSE,

There is no SUBPART O

300

TRUE OR FALSE,

A COMPANY WITH A LABORATORY CAN MAKE A PROPER WASTE DETERMINATION BASED ON ITS OWN ANALYSIS?

COULD BE TRUE or FALSE,

A COMPANY could do this but if not following correct test method and using VELAP lab, can be required to do another HW determination

400

WHEN DID THE GIR BECOME EFFECTIVE IN VIRGINIA?

April 8, 2018

400

BY WHAT DATE MUST A VSQG SUBMIT A FORM 8700-12 TO OPT INTO SUBPART P?

There is no specific time frame to opt in for VSQGs, however cannot manage as HWP until they have opted in

400

HOW LONG DOES A REVERSE DISTRIBUTOR HAVE TO ESTABLISH CREDIT FOR POTENTIALLY CREDITABLE HW PHARMS?

30 days

400

HOW MANY TIMES PER MONTH MUST A HEALTHCARE FACILITY INSPECT ITS POTENTIALLY CREDITABLE HW PHARMS?

Weekly, so approximately four times per month

400

BY WHAT DATE MUST A LQG SUBMIT A REVISED NOTIFICATION TO INCLUDE SUBPART P?

October 22, 2019

500

WHAT THINGS MUST APPEAR ON A HW LABEL IN A SATELLITE ACCUMULATION AREA?

The words hazardous waste and an indication of the hazard of the waste

500

WHO MUST SIGN AN EPA FORM 8700-12?

Generator(s), owner(s), operator(s) or authorized representative(s)

500

AT WHAT FREQUENCY IF ANY MUST A REVERSE DISTRIBUTOR INVENTORY HW PHARMACEUTICALS ON SITE?

Continuously within 30 days of arrival

500

AS OF 10/17/2019, HOW MANY STATES HAVE ADOPTED THE PHARMACEUTICALS RULE

Six have adopted, 2 more had it take effect because state not authorized

500

HOW LONG MUST AN OPERATING UNIT BE OUT OF SERVICE BEFORE THE MATERIALS IN IT BECOME WASTE?

90 days

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