Environmental/Feb 1, 2016

Michigan Changes “Liquid Industrial Waste” to “Liquid Industrial By-Products”, Eliminates Site ID and Manifesting Requirements

In December of 2015, the Michigan legislature passed Senate Bill 400, amending Part 121 (Liquid Industrial Wastes) of the Natural Resources and Environmental Protection Act (NREPA), making the following significant changes:

  • The title of Part 121 was changed to “Liquid Industrial By-Products” and all internal references throughout Part 121 were changed from “liquid industrial waste” (LIW) to “liquid industrial by-products” (LIB).
  • The requirement for a LIB generator to obtain a Site Identification Number when LIBs are to be transported off-site was eliminated.
  • The requirement for a LIB generator to use a Uniform Hazardous Waste Manifest for off-site transportation of LIB was eliminated. A shipping document is still required, with revised requirements included in Part 121 (a shipping document may include an invoice, bill of lading, or other record, provided it includes specific information). Proper LIB tracking and recordkeeping is still required.
  • Tanks and containers of LIB must be properly labeled or marked to identify their contents.
  • Materials that are used/reused as an effective substitute for commercial products, used as an ingredient to make a product, or returned to the original process (if material does not need reclamation) are not classified as LIB. This exemption does not apply to materials directly burned to recover energy or applied to the land.

SB-400 (designated Public Act 224 of 2015) becomes effective 90 days after Gov. Snyder’s signature (March 16, 2016). Although this amendment does not become fully effective until March of 2016, the DEQ has determined that it will allow utilization of these revisions now.

For a full reading of the newly-amended Part 121, click on the following link:



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