Brittanysays:

Hi Angela!

In November 2016, the EPA revised some of the hazardous waste rules for all types of generators. Conditionally Exempt Small Quantity Generators (CESQGs) are now called Very Small Quantity Generators (VSQGs). Under the new rule, VSQGs still need to make hazardous waste determinations and do recordkeeping, but many of their other management requirements have been revised and collected into 40 CFR 264.14. This paragraph does not contain a provision for VSQGs to have communication systems.

However, there may be other reasons to have robust communication systems throughout your campus. For example, communication systems may be an important component of your campus Emergency Action Plan, required by OSHA [29 CFR 1910.38].

It is important for both the environmental and safety managers to review the specific hazards and risks in the chemistry labs, maintenance shops and other areas where hazardous wastes are generated on campus to ensure that there are adequate communication systems that can be used by anyone to report spills, fires or other emergencies. Depending upon the severity of the risks, phones may be sufficient – but it is best for the specific hazards and risks to be reviewed locally before that type of determination can be made.

Hope this info is helpful!

Thanks,
Brittany