Hazardous waste generators - District of Columbia

The District of Columbia (DC) adopts the federal hazardous waste regulations (40 CFR Parts 260-273), but it also includes additional local requirements under the DC Municipal Regulations (DCMR), Title 20, Chapter 42. These additions make DC’s hazardous waste rules slightly more stringent than federal rules.

Below is a summary of the key differences:

• Regulatory Authority – DC is regulated by the Department of Energy and Environment (DOEE). The DOEE enforces both the federal rules and additional DC specific rules. (Federal: Regulated by the EPA under RCRA)
• Notification and Permitting – DC requires generators to register directly with DOEE and obtain a DC Generator ID Number, even if already registered with the EPA. You must also notify DOEE of any changes in generator status, location, or operations.
• Hazardous Waste Determination – Follows federal, but also includes “DC Hazardous Waste”, which is any waste that poses a public threat to public health or the environment as determined by the DOEE director.
• Labeling and Container Management – DC requires more detailed labels, including generator name and address, contents and hazard description, and emergency contact phone number.
• Training Requirements – All generator categories must ensure employees are trained in hazardous waste handling procedures. Additional training is required for facilities under a Hazardous Materials Management Plan (HMMP).
• Waste Accumulation and Storage – Follows federal guidelines.
• Manifest and Reporting Requirements – Biennial reporting required for all LQGs, but DC has authority to request reports from other generator categories. Facilities must submit manifest to both the EPA and DOEE.