Vermont Containers regulations & environmental compliance analysis

Vermont Containers: What you need to know

Governing Law and Regulations

Container management requirements and organic air emissions standards: Vermont Administrative Rule (VAR) 12-032-001 Section 7-504(e)(1) and VAR 12-032-001 Section 7-510(c)(1) Empty container rules: : VAR 12-032-001 Section 7-203(j)

Regulatory Agency
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Vermont Agency of Natural Resources Department of Environmental Conservation (DEC) Waste Management Division Hazardous Waste Management Program

Comparison: State vs. Federal

· Rules. Vermont has adopted, by reference, the federal hazardous waste container and the organic air emissions standards and its empty container standards follow the federal requirements. The state requirements for generators using containers to accumulate hazardous waste on-site without a permit follow the federal rules and add more stringent state provisions relating to the areas where the containers are kept, marking, inspections, and records. For more information on these generator requirements, see the state section HAZARDOUS WASTE STORAGE.

· Administration and enforcement. DEC's Waste Management Division administers and enforces the container rules in Vermont.

State Requirements



Vermont follows the federal hazardous waste accumulation rules for generators but defines its generator classifications in pounds and has more stringent requirements for LQGs, SQGs, and CESQGs. The state refers to the place where a generator's hazardous waste is accumulated as the generator's "short-term storage area" and has requirements in connection with the area's design and operating standards that are in addition to the federal requirements. Its satellite accumulation provisions are also more stringent than the federal requirements ...

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