While Congress ponders stiffer legislation on hazardous-waste disposal, the Environmental Protection Administration's Office of Solid Waste has proposed giving states an additional two years or more to bring their programs into compliance with any changes in federal toxic-waste laws.

". . . Changes in the federal program in the coming months may well delay final authorization of state programs if the federal program becomes a 'moving target,' " the agency said in a Federal Register notice yesterday.

An EPA official said the proposal had nothing to do with pending legislation to reauthorize the Resource Conservation and Recovery Act, the law that is supposed to govern toxic waste "from cradle to grave." Congress is considering plugging several loopholes in the law and significantly narrowing an exemption for waste generated by small businesses.

But in yesterday's notice, the EPA acknowledges that its proposal could open, for a "minimal" time, a window in which state-run programs would not be as stringent as federally run programs, as the law requires. Under RCRA, as with other major environmental laws, states have the choice of letting the federal government run the program or designing plans to run it themselves.

"In practical terms, the effect of this proposed rule is that all states would have either 18 or 30 months from the time changes are made in the federal program to make conforming changes in their own programs," the EPA said.

Denise Hawkins of the solid waste office said the "moving target" proposal was simply an effort "to give states a reasonable amount of time to change their regulations." The EPA is reviewing its hazardous-waste rules, she said, but "in the short term it's not clear" that any will be revised. AND ON ANOTHER FRONT . . . Starting in November, chemical manufacturers and processors will be required to keep records of complaints that their products have caused damage to human health or the environment.

Congress put the record-keeping requirement in the 1976 Toxic Substances Control Act. But it took the agency until this week to publish its final rule, which is much less stringent than its original proposal three years ago but still stiff enough to bring growls from the chemical industry.

"We're going to be spending a lot of money keeping track of allegations, many without merit," said Tom Gilroy of the Chemical Manufacturers Association. "It is a potentially big cost with little benefit."

The CMA didn't have any cost estimates, but the EPA figured the new rule will cost the companies $15 million at the outset and about $2 million a year after that. Manufacturers and processors--but not retailers or distributors--will have to keep complaints from employes on file for 30 years, and other complaints for five years. About 10,000 companies will be affected.

The EPA will have the right to inspect the records, and said it hoped chemical firms would use them as well to identify potential problems with their products. Gilroy said most chemical firms already are "very diligent" about that, but added, "To the extent that it will promote stewardship, it will be a good rule." EAT YOUR HEART OUT, RITA LAVELLE . . . It was a proper comeuppance for the Washington press corps, so quick to heap scorn on public servants who quiet their midday tummy rumbles at the expense of fat-cat lobbyists and political favor-seekers.

William D. Ruckelshaus invited a crew of EPA-beat regulars to lunch--and told them to bring their own.

Up to the administrator's penthouse-level dining room they trekked, paper bags in hand, yogurt stuffed in purses, for the first of what EPA officials say will be regular "brown-bag lunches" with rotating groups of reporters.

Environmental Health Letter editor Gershon Fishbein came with a cup of coffee, allowing as how he forgot to pack a lunch. Wall Street Journal correspondent Andy Pasztor peered into his fridge, found little of a brown-bag persuasion inside, and came with a pear and two plums.

Eleanor Randolph of the Los Angeles Times brought the proper California repast--a carry-out salad and carbonated apple juice. Associated Press stalwart Martin Crutsinger opted for tradition: lunch meat on sliced bread and a baggie of cookies.

Ruckelshaus came late to the table, where a hero sandwich and bottle of caffeine-free soda awaited him. While reporters, who had already devoured their meager meals, politely held back their questions, Ruckelshaus gave his lunch a critical look.

"Go ahead," he said. "I'm not going to eat much of this."