Washington RCRA for Manufacturing: Cybersecurity Requirements

 

The Resource Conservation and Recovery Act (RCRA) in Washington State has specific cybersecurity implications for manufacturing facilities that handle hazardous waste. Unlike general cybersecurity frameworks, Washington's implementation includes digital security requirements tailored to environmental protection and hazardous materials management.

 

Key Washington RCRA Cybersecurity Requirements for Manufacturers

 

• Electronic Manifest System (e-Manifest) Security: Washington manufacturers must implement specific security protocols when using the EPA's e-Manifest system for tracking hazardous waste, including multi-factor authentication and secure data transmission standards specific to the Pacific Northwest region's regulatory environment.
• Washington Department of Ecology Reporting System Protection: Manufacturing facilities must secure connections to Washington's Secure Access Washington (SAW) portal when submitting required hazardous waste reports, with data encryption requirements exceeding federal standards.
• Industrial Control System (ICS) Security for Waste Treatment: Washington manufacturers with on-site waste treatment systems must implement ICS protections aligned with Washington Administrative Code (WAC) 173-303 requirements, focusing on preventing unauthorized access to waste management equipment.
• Dangerous Waste Information Management: Digital systems storing information about dangerous waste under Washington's designation (which includes wastes beyond federal RCRA lists) require specific data protection controls.

 

Washington-Specific Compliance Requirements

 

• Washington Electronic Signature Requirements: Manufacturers must implement specific digital signature protocols compliant with Washington State's Electronic Authentication Act when submitting RCRA documentation electronically.
• Cascadia Corridor Data Protection: Manufacturing facilities near the Canadian border have additional data security requirements when waste crosses international boundaries, including specific encryption standards.
• Puget Sound Industrial Waste Digital Monitoring: Manufacturers in the Puget Sound region must implement specialized cybersecurity controls for digital monitoring systems tracking industrial waste that could impact waterways.

 

Security Measures Required for Washington Manufacturers

 

• Access Control Systems: All digital systems handling RCRA data must implement role-based access controls with specific Washington Department of Ecology audit logging requirements.
• Network Segmentation: Manufacturing networks controlling waste treatment or storage systems must be segmented from business networks, with specific firewall configurations required under WAC guidelines.
• Incident Response Planning: Washington manufacturers must develop cyber incident response plans that specifically address environmental reporting requirements if systems managing hazardous waste are compromised.
• Vulnerability Management: Regular vulnerability scanning of systems handling RCRA data with priority remediation for systems connected to waste treatment equipment, meeting Washington-specific testing frequencies.

 

Penalties for Non-Compliance

 

• Washington-Specific Fines: Non-compliance with digital security requirements for RCRA systems can result in penalties up to $10,000 per day per violation under Washington State enforcement guidelines.
• Mandatory Reporting: Security breaches affecting RCRA data systems must be reported to the Washington Department of Ecology within specific timeframes not required in other states.
• Increased Inspection Frequency: Facilities with identified cybersecurity deficiencies face more frequent Washington Department of Ecology inspections focused on digital controls.

 

Implementation Steps for Washington Manufacturers

 

• Conduct a Washington RCRA-Specific Security Assessment: Evaluate all digital systems that interact with hazardous waste management against Washington's specific requirements.
• Develop Integrated Compliance Documentation: Create documentation that addresses both environmental compliance and cybersecurity requirements specific to Washington State.
• Implement Technical Controls: Deploy required security technologies with configurations that meet or exceed Washington Department of Ecology standards.
• Train Personnel: Provide specialized training on Washington RCRA cybersecurity requirements for both environmental compliance and IT staff.
• Establish Ongoing Monitoring: Implement continuous monitoring of systems handling RCRA data with Washington-specific alerting thresholds.

 

Resources for Washington Manufacturers

 

• Washington Department of Ecology: Offers manufacturer-specific guidance on securing systems that handle dangerous waste information.
• Pacific Northwest National Laboratory (PNNL): Provides regional industrial cybersecurity resources specific to manufacturing environments handling hazardous materials.
• Washington State Office of Cybersecurity: Offers guidance on complying with Washington-specific electronic reporting security standards.