['Waste']
['Empty Containers', 'Waste Generators', 'Waste Identification', 'Hazardous Waste', 'Solid Waste', 'Incompatible Wastes', 'Waste Management', 'Special Waste']
08/29/2024
Copyright 2025 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.
...
EPA’s hazardous waste regulations apply differently depending upon your generator category, which is determined by how much hazardous waste you generate each month. The more waste you generate, the more regulated you are.
Small Quantity Generators (SQGs) generate between 220 and 2,200 pounds of hazardous waste per month, 2.2 pounds or less of acute hazardous waste, and 220 pounds or less of residues from a cleanup of acute hazardous waste generated in a calendar month. They are more regulated than VSQGs, but less regulated than LQGs.
Scope
Hazardous waste generators must count up all the waste they generate each month to determine their generator category. In addition, they must not accumulate more waste than is allowed for their category at any one time.
There are three categories of hazardous waste generators:
- Very Small Quantity Generators (VSQGs, formerly known as Conditionally Exempt Small Quantity Generators);
- Small Quantity Generators (SQGs); and
- Large Quantity Generators (LQGs).
VSQGs generate the least amount of hazardous waste per month and LQGs generate the most.
Generators must comply with a specific set of requirements for their specific generator category.
Regulatory citations
- 40 CFR 261 — Identification and listing of hazardous waste
- 40 CFR 262.16 — Conditions for exemption for a small quantity generator that accumulates hazardous waste
Key definitions
- Acute hazardous waste: Any hazardous waste with a “P” waste code (or certain “F” waste codes). These wastes are subject to stringent accumulation and management requirements.
- Accumulate: To store hazardous waste on-site for a regulated amount of time before shipping it off-site. Generators have accumulation time limits as well as quantity limits.
- Biennial report: A report submitted by hazardous waste LQGs and Treatment, Storage, and Disposal Facilities (TSDFs) (and Small Quantity Generators after 2020) to enable EPA and the states to track the quantities of hazardous waste generated and the movements of those hazardous wastes.
- Central Accumulation Area (CAA): An area where a hazardous waste generator collects marked and dated hazardous waste. Waste in a CAA may only be accumulated for 90 days or 180 days, depending on the generator’s hazardous waste category.
- Counting: Totaling the hazardous wastes at a given facility for a particular month in order to determine hazardous waste generator status.
- Cradle to grave: The time period from the initial generation of hazardous waste to its ultimate disposal.
- Designated facility: The TSDF that has been designated on the manifest by the generator. These facilities must have a RCRA permit (or interim status), or be recycling facility regulated under 40 CFR 261.2(c)(2) or 266 Subpart F.
- EPA identification number: The unique number assigned by EPA to each hazardous waste generator, transporter, or treatment, storage, and disposal facility.
- Episodic generation: The situation in which a generator’s status changes from one month to the next, as determined by the amount of waste generated in a particular month. If a generator’s status does in fact change, the generator is required to comply with the respective regulatory requirements for that class of generators for the waste generated in that particular month.
- Generator: Any person, by site, whose act first creates or produces a hazardous waste or used oil, or first brings such materials into RCRA regulation.
- Hazardous waste: Waste with properties that make it dangerous or capable of having a harmful effect on human health and the environment. Under RCRA, hazardous wastes are specifically defined as wastes that meet a particular listing description or that exhibit a characteristic of hazardous waste.
- Listed wastes: Wastes that are considered hazardous under RCRA because they meet specific listing descriptions. These lists are found in 40 CFR 261 Subpart D.
- Manifest (universal hazardous waste manifest): The paperwork that accompanies hazardous waste from the point of generation to the point of ultimate treatment, storage, or disposal. Each party involved in the waste’s management retains a copy of the RCRA manifest, which contains specific information about the waste.
- RCRA: The Resource Conservation and Recovery Act, which is the nation’s solid and hazardous waste management law.
- Small Quantity Handler of Universal Waste (SQHUW): A handler that does not accumulate 5000 kg of all universal waste categories combined at a location at any onetime.
- Tanks: Stationary containers used to store or treat hazardous waste.
- Use constituting disposal: The direct placement of wastes or waste-derived products (e.g., asphalt with petroleum refining wastes as an ingredient) on the land.
- Used oil: Any oil that has been refined from crude or synthetic oil that has been used and, as a result of such use, is contaminated by physical or chemical impurities. Used oil may be managed under the relaxed management standards at 40 CFR 279.
Summary of requirements
Basic requirements for SQGs:
- Identify all hazardous waste generated.
- Obtain an EPA Hazardous Waste Generator ID number.
- Ship waste offsite within 180 days (or 270 days if shipping a distance greater than 200 miles).
- Do not accumulate more than 13,000 pounds of waste on site at any one time.
- Ensure there is always at least one employee available to respond to an emergency. This employee is the emergency coordinator responsible for coordinating all emergency response measures. SQGs are not required to have detailed, written contingency plans.
- Store waste in proper containers (no leaks, bulges, etc.).
- Properly mark and label waste containers.
- Train employees in basic waste management and emergency procedures.
- Ship waste offsite using the hazardous waste manifest.
- Submit annual waste report to state (if required) and submit SQG re-notification every four years beginning in 2021 (new with the Hazardous Waste Generator Improvements Rule (HWGIR).
READ MORESHOW LESS
['Waste']
['Empty Containers', 'Waste Generators', 'Waste Identification', 'Hazardous Waste', 'Solid Waste', 'Incompatible Wastes', 'Waste Management', 'Special Waste']
Load More
J. J. Keller is the trusted source for DOT / Transportation, OSHA / Workplace Safety, Human Resources, Construction Safety and Hazmat / Hazardous Materials regulation compliance products and services. J. J. Keller helps you increase safety awareness, reduce risk, follow best practices, improve safety training, and stay current with changing regulations.
Copyright 2025 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.