Very small quantity generator (VSQG)

Scope

There are three categories of hazardous waste generators:

Regulatory citations

• 40 CFR 262.14 — Conditions for exemption for a very small quantity generator

Key definitions

• Acute hazardous waste: Hazardous wastes that meet the listing criteria in 261.11(a)(2) and therefore are either listed in 261.31 with the assigned hazard code of (H) or are listed in 261.33(e).
• Condition for exemption: The requirements that must be followed to keep a facility from being considered a treatment, storage, and disposal facility (TSDF) when the facility accumulated hazardous waste onsite. For instance, if a very small quantity generator produces more than 220 pounds of hazardous waste in a month, the generator has not met the condition for exemption from being considered a larger generator or a Treatment, Storage, and Disposal Facility (TSDF).
• Conditionally exempt small quantity generator: The old federal term for very small quantity generator.
• Hazardous waste generator: Any person, by site, whose act or process produces hazardous waste or whose act first causes a hazardous waste to become subject to regulation.
• Large quantity generator (LQG): A facility that generates:
  • Greater than or equal to 2,200 pounds of non-acute hazardous waste; or
  • Greater than 2.2 pounds of acute hazardous waste or
  • Greater than 220 pounds of any residue or contaminated soil, water, or other debris resulting from the cleanup of a spill, into or on any land or water, of any acute hazardous waste.
• Small quantity generator (SQG): A facility that generates the following amounts in a calendar month:
  • Greater than 220 pounds but less than 2,200 pounds of non-acute hazardous waste; and
  • Less than or equal to 2.2 pounds of acute hazardous wastes; and
  • Less than or equal to 220 pounds of any residue or contaminated soil, water, or other debris resulting from the cleanup of a spill, into or on any land or water, of any acute hazardous waste.
• Very small quantity generator (VSQG): A facility that generates the following amounts in a calendar month:
  • Up to 220 pounds of non-acute hazardous waste; and
  • Up to 2.2 pounds of acute hazardous waste; and
  • Up to 220 pounds of any residue or contaminated soil, water, or other debris resulting from the cleanup of a spill, into or on any land or water, of any acute hazardous waste.

Summary of requirements

Basic requirements for VSQGs:

• Identify all hazardous waste generated.
• Do not accumulate more than 2,200 pounds of hazardous waste at any time.
• Ensure that hazardous waste is delivered to a person or facility authorized to manage it.

Be sure to check the state-level requirements in this area. Remember, any state can pass more stringent regulations than the federal ones. Many states have more stringent requirements for VSQGs, including requiring manifests for waste shipments from these generators.

VSQG Waste Sent to LQGs. EPA’s 2016 rule known as the Hazardous Waste Generator Improvements Rule (HWGIR) simplified the shipping of VSQG waste offsite. The HWGIR allows VSQGs to ship waste to an LQG that is under the control of the same person. EPA says this will reduce the overall time that the VSQG accumulates hazardous waste on site, thus better protecting the environment. (Note that not all states allow this practice.)

The VSQG must mark containers of hazardous waste sent to LQGs with:

• The words “Hazardous Waste,” and
• An indication of the hazards of the contents.