Safety & Compliance News

Paper submissions coming to an end

NH is now meeting the requirements of the Federal Motor Carrier Safety Administration (FMCSA) and will no longer accept paper copies of the Medical Examiner Certificates (med cards), including drop box, email, and in-person submissions. The last paper copy was accepted on August 14, 2026.

Two states left

LA and AK are the final two states to comply with the FMCSA’s requirement for receiving med cards electronically and directly from a certified examiner. CDL drivers in these states must continue to submit their med card information directly to the state.

The FMCSA has a current exemption in place until October 11, 2026, which allows CDL holders and carriers to use a copy of a CDL driver’s DOT med card for up to 60 days to show proof of medical certification. This exemption was issued to allow the remaining states time to transition to the NRII process, as well as address issues with transfer delays in states that have already implemented the NRII process.

NRII background

Since June 23, 2025, the “National Registry II” dictated that if a certified medical examiner finds that a CDL driver is physically qualified to drive a CMV, the examiner will complete a CMV Driver Medical Examination Results Form (MCSA-5850) in the National Registry of Certified Medical Examiners (NRCME). That information will be electronically transferred to the driver's licensing authority. Upon receiving this information, the state will post a medical qualification status of “certified” on the driver’s motor vehicle record (MVR), along with other required exam information. The driver’s state driving record (i.e., MVR) is official proof of medical certification for CDL drivers and their carrier.

None of these changes apply to non-CDL drivers, who must follow all existing regulations concerning physical qualification status.

The clock

Under federal regulation, the 90-day accumulation clock for a large quantity generator (LQG) starts the moment the first drop of hazardous waste enters a container in a Central Accumulation Area — not when the container is full, not when it's staged for pickup, and not when someone gets around to labeling it. LQGs have 90 days to ship waste off-site; small quantity generators (SQGs) get 180 days or 270 days if the disposal facility is more than 200 miles away. If that date is missed, your storage area becomes an unpermitted TSDF, with penalties reaching into the tens of thousands of dollars per day.

Why "episodic" automatically means excused

Sometimes employers can assume that an unusual event such as a tank cleanout or spill response buys them some flexibility on the time limits. It can, but only if you follow a specific and narrow procedure. Under the Hazardous Waste Generator Improvements Rule, a facility can ship waste from an episodic event off-site without triggering a change to its normal generator category, but only if the generator notifies EPA or the state at least 30 days before a planned event, or within 72 hours after an unplanned one, and concludes the episodic event within 60 days, including transporting the waste off-site.

An SQG is limited to one episodic event per calendar year, though a second event may be approved if a petition is granted. If the hazardous waste from the event isn't off-site within that 60-day window, it gets counted toward the generator's regular monthly generation levels, which can bump a facility into a more heavily regulated generator category it never intended to occupy. In other words, episodic status is a documented exception you apply for, not a category you default into because the circumstances felt unusual. Treating it as the latter is exactly how a facility ends up discovering, mid-inspection, that its "one-time" waste has been sitting well past both the episodic window and the standard accumulation limit.

The cost of losing track

Civil penalties under RCRA Subtitle C now reach $93,058 per day per violation, and separate analysis puts the current statutory ceiling for the most common RCRA civil penalties at $124,426 per day per violation. A drum without a date, a missed weekly inspection entry, an expired training record, or an untracked manifest can each become a standalone liability, but exceeding accumulation time limits remains the single most costly and most preventable category that EPA inspectors encounter.