Hazardous waste generators - California

California’s hazardous waste generator rules are more in-depth and stricter than the federal rules. They apply to a broader range of wastes, including stricter container, training, and recordkeeping requirements.

A summary of the requirements and differences includes the following:

• Waste Determination – Uses more than 40 additional hazardous waste codes not recognized by the EPA and has a broader definition of ‘Hazardous Waste.” California also has non-RCRA hazardous waste (state only regulated waste) like used oil filters and antifreeze.
• Waste Generator Categories – Does not officially use the term “Very Small Quantity Generator” and instead refers to conditionally exempt small quantity generators (CESQG). They also have additional tracking and reporting requirements even for small quantity generators.
• Accumulation time limits – Same time limits as federal requirements.
• Satellite Accumulation Areas – Follows the same limits (55 gallons of hazardous waste or 1 quart of acutely hazardous).
• Training Requirements – California requires annual training for all generators, even CESQGs in some jurisdictions (federal only requires annual for large quantity generators.
• Manifesting and Transport – Requires state specific manifest forms for certain shipments and applies manifest requirements for more types of waste. Additionally, transporters are required to have a California Hazardous Waste Transported Registration and use only registered facilities.
• Container Management – Containers must be labeled with “Hazardous Waste”, accumulation start date, waste composition and physical state, and hazardous properties. California also requires weekly inspections of all hazardous waste areas.
• Reporting – California facilities must submit an annual facility report. Large quantity generators in California must also submit the EPA’s Biennial Hazardous Waste report.
• Waste Minimization – California requires waste minimization plans under the Hazardous Waste Source Reduction and Management Review Act for LQGs.