Hazardous waste records and reports

Scope

The extent of your recordkeeping and reporting requirements depends upon your generator category and any additional obligations that may be required by your state.

Regulatory citations

• 40 CFR 262.18 — EPA identification numbers and re-notification for small quantity generators and large quantity generators. 
• 40 CFR 262.41 — Biennial report for large quantity generators. 
• 40 CFR 262.56 — Annual reports

Key definitions

• Biennial report: The report completed by Large Quantity Generators every even-numbered year that tracks the generator’s waste activities.
• Hazardous waste number: The number (or code) assigned by the EPA to each hazardous waste listed in 40 CFR Part 261 Subpart D and to each characteristic identified in 40 CFR Part 261 Subpart C. The codes consist of one letter (D, F, P, U, or K) and three numbers.
• Hazardous waste management: The systematic control of the collection, source separation, storage, transportation, processing, treatment, recovery, or disposal of hazardous waste.
• Notification: Notifying the state or EPA region of a generator’s waste activities.
• Recycling: The use, reuse, or reclamation of a material (40 CFR 261.1(c)(7)). “Reclamation” is the processing or regeneration of a material to recover a usable product (e.g., recovery of lead values from spent batteries, regeneration of spent solvents) (40 CFR 261.1(c)(4)). A material is “used or reused” if it is either: (1) employed as an ingredient (including use as an intermediate) in an industrial process to make a product (e.g., distillation bottoms from one process used as feedstock in another process) (40 CFR 261.1(c)(5)). However, a material will not satisfy this condition if distinct components of the material are recovered as separate end products (as when metals are recovered from metal-containing secondary material); or (2) a commercial product (e.g., spent pickle liquor used as phosphorous precipitant and sludge conditioner in wastewater treatment).
• Waste minimization: The reduction, to the extent feasible, of hazardous waste that is generated or subsequently treated, stored, or disposed. It includes any source reduction or recycling activity undertaken by a generator that results in: 1.) the reduction of total volume or quantity of hazardous waste; 2.) the reduction of toxicity of hazardous waste; or 3.) both, as long as the reduction is consistent with the goal of minimizing present and future threats to human health and the environment.

Summary of requirements

Small quantity generators:

• Keep required waste characterization documentation.
• Keep completed manifests on file for three years.
• Keep required LDR notifications.
• Keep training records for facility personnel.
• Complete state re-notification every four years beginning in 2021.
• Complete annual report for exports.

Large Quantity Generators:

• Keep required waste characterization documentation.
• Keep completed manifests on file for three years.
• Keep required LDR notifications.
• Keep training records for facility personnel.
• Submit biennial report by March 1^st on every even-numbered year.