Understanding Texas RCRA for Manufacturing Cybersecurity

 

The Resource Conservation and Recovery Act (RCRA) in Texas has specific cybersecurity implications for manufacturers that handle hazardous waste. While RCRA is primarily an environmental regulation, modern compliance requires robust data security practices.

 

Texas RCRA Cybersecurity Fundamentals

 

In Texas, the Texas Commission on Environmental Quality (TCEQ) administers RCRA regulations with state-specific requirements that affect how manufacturing facilities must secure their waste management data systems.

 

• Texas Waste Data Security Requirements: Manufacturers must maintain secure electronic records of hazardous waste generation, transportation, and disposal for at least 3 years (longer than some other states)
• TCEQ Electronic Reporting: Texas manufacturers must use secure channels when submitting electronic hazardous waste reports through the STEERS (State of Texas Environmental Electronic Reporting System)
• Texas Industrial Solid Waste (ISW) Numbers: Each facility's unique identifier must be protected against unauthorized access that could lead to waste fraud

 

Texas-Specific Electronic Manifest System Security

 

Texas manufacturers using the e-Manifest system face specific cybersecurity challenges:

 

• Two-factor authentication is required for Texas manufacturing facilities accessing the e-Manifest system
• Texas-specific API security protocols must be followed when integrating manufacturing waste management systems with TCEQ reporting platforms
• User access controls must limit e-Manifest system access to authorized personnel with specific waste management responsibilities
• Annual cybersecurity training is required for all Texas manufacturing staff who handle electronic waste records

 

Data Protection for Texas Hazardous Waste Information

 

• Encrypted storage of all electronic waste determination documentation, particularly for Texas-listed hazardous wastes
• Secure backup systems for all waste manifests and TCEQ correspondence with off-site redundancy (required by Texas state regulations)
• Chain-of-custody documentation must be digitally secured with audit trails showing who accessed or modified waste records
• Texas-specific retention periods: Electronic waste records must be maintained securely for minimum 3-year periods, with some records requiring 30+ years of secure storage

 

RCRA Security in Texas Manufacturing Facilities

 

• Physical access controls must be in place for computers and terminals that access waste management data
• Network segmentation separating waste management systems from general manufacturing networks
• Texas Critical Infrastructure protection for manufacturers designated as critical infrastructure under Texas state guidelines
• TCEQ-compliant incident response plans specifically addressing breaches involving regulated waste data

 

Special Requirements for Texas Chemical Manufacturers

 

• Enhanced cybersecurity protocols for manufacturers in Texas chemical corridors (Houston Ship Channel, Beaumont-Port Arthur, etc.)
• Texas Risk Management Program (RMP) data security requiring additional protection for information about extremely hazardous substances
• Texas Tier II Chemical Reporting security requiring protection of sensitive chemical inventory data from unauthorized access

 

Compliance Verification and Auditing

 

• TCEQ cybersecurity audits may be conducted as part of routine RCRA inspections at Texas manufacturing facilities
• Texas Environmental, Health & Safety (EHS) software validation requirements to ensure data integrity
• Third-party security assessments are recommended for Texas manufacturers handling large quantities of hazardous waste
• Documentation of security controls must be available during TCEQ inspections

 

Penalties for Non-Compliance in Texas

 

• Texas-specific fines for data security breaches affecting hazardous waste information can range from $1,000 to $25,000 per day per violation
• Potential criminal penalties for intentional falsification or destruction of electronic waste records
• TCEQ enforcement actions may include mandated security upgrades with strict implementation timelines

 

Resources for Texas Manufacturers

 

• TCEQ Small Business Assistance Program offers cybersecurity guidance specific to waste management requirements
• Texas Manufacturing Assistance Center (TMAC) provides technical support for implementing secure waste tracking systems
• Texas Association of Manufacturers offers industry-specific best practices for RCRA cybersecurity compliance

 

Implementing a Secure RCRA Program in Texas Manufacturing

 

• Designate a Texas RCRA cybersecurity coordinator responsible for ensuring data protection measures meet state requirements
• Conduct regular vulnerability assessments focused on waste tracking and reporting systems
• Develop Texas-compliant disaster recovery plans for waste management data that meet both TCEQ and federal requirements
• Implement secure channels for communicating with TCEQ and EPA regarding waste management