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Calculating Monthly Hazardous Waste Totals

Hazardous waste generators must calculate the total weight of hazardous waste generated each month to determine their generator category — Very Small Quantity Generator (VSQG), Small Quantity Generator (SQG), or Large Quantity Generator (LQG). This includes any acutely hazardous waste (which must be counted separately) as well as any hazardous waste generated at satellite accumulation areas (SAAs).

This checklist will help you calculate your monthly hazardous waste totals by enumerating what to count — and, just as important, listing what NOT to count when making your monthly assessment.

Calculate your monthly hazardous waste total using the following checklist to note your totals, and then apply these totals to the formula:

Perform your generator calculations on the first day of each month.Date:
Calculate the total weight of all full hazardous waste containers placed into storage (i.e., your central accumulation area (CAA)) during the prior month. Calculate this total weight in pounds or kilograms, and be consistent with your standard of measure throughout.
Note: Do not include the weight of the containers themselves!
Total weight placed in CAA for past month:(lbs/kgs)
Calculate the total weight of all the waste in satellite accumulation containers in SAAs.Total weight in SAA accumulation containers:(lbs/kgs)
Note the total weight of the waste in satellite containers from the previous month. This weight has already been counted, but may still be present either in satellite containers or in a container since moved to a CAA.Total weight in SAA accumulation containers from previous month:(lbs/kgs)

Formula to calculate monthly total (Remember: Acute hazardous waste calculations must be completed separate from nonacute hazardous waste calculations to determine your generator category):

Total weight placed in CAA in past monthlbs/kgs
PLUS (+) Total weight in SAA accumulation containers +
MINUS (–) Total weight in SAA accumulation containers from previous month -
Monthly hazardous waste total: lbs/kgs
Don’t include the following in your monthly hazardous waste generation totals! These items must be managed separately, not counted at all, or you should subtract their weights from your monthly total:
  • Exempted wastes. Any waste found to be an exempt waste in the course of determination/identification should not be included in your monthly calculations.
  • Used oil (unless you manage it as a hazardous waste). Used oil not managed as a hazardous waste must be managed in accordance with 40 CFR 279 and any relevant state-specific regulations regarding used oil.
  • Universal waste. These commonly generated wastes must be managed separately in accordance with 40 CFR 273 and any relevant state-specific definitions and regulations surrounding universal waste.
  • Residue from “RCRA-empty” containers. A RCRA-empty container may be disposed of as a solid waste and should not be counted with hazardous waste totals.
  • Waste that you’ve already counted. This mistake may be made by counting slow-accumulating waste, especially in SAAs, more than once. The formula above takes this into account, but be sure to remain vigilant of your total monthly accumulation in these waste management areas.
  • The weight of the containers themselves. EPA allows generators to back out the container weight, and while this may be a small amount, it could potentially affect generator status.

Consult the full regulation at 40 CFR 262.13: Generator category determination for additional details.