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Quick Reference: Comparing Hazardous Waste Generator Requirements and Universal Waste Requirements

Hazardous waste generators of various sizes have different requirements than universal waste generators. Use this quick reference table to compare hazardous waste generator requirements and universal waste generator requirements.

Federal regulatory citations:

40 CFR 260

40 CFR 262

40 CFR 273

Universal Waste Requirements Hazardous Waste Generator Requirements
Small Quantity Handler of Universal Waste (SQHUW) Large Quantity Handler of Universal Waste (LQHUW) Very Small Quantity Generator (VSQG) Small Quantity Generator (SQG) Large Quantity Generator (LQG)
Quantity Handled by CategoryAccumulate < 5,000 kg (11,000 lb) onsite at any one time Accumulate 5,000 kg (11,000) or more onsite at any one timeProduce < 100 kg (220 lb) per month < 1 kg acute* per month < 1 kg per month of acute spill residue or soil Produce >100 and < 1,000 kg (2,200 lb) per month Produce > 1,000 kg per month > 1 kg acute* per month or >100 kg per month of acute spill residue or soil
EPA Identification Number Not required Required Not requiredRequiredRequired
Onsite Accumulation Limit< 5,000 kg No quantity limit < 1,000 kg < 1 kg acute* < 100 kg acute spill residue or soil < 6,000 kg No quantity limit
Storage Time Limit (without a storage permit) 1 year, unless for proper recovery, treatment, or disposal 1 year, unless for proper recovery, treatment, or disposal None< 180 days or < 270 days (if transporting greater than 200 miles) < 90 days
Manifest Not required Not required, but must keep basic shipping records Not requiredRequiredRequired
Personnel Training Basic training Basic training geared toward employee responsibilities Not requiredBasic training requiredRequired