Small Quantity Generators of Hazardous Waste (SQG's)

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This page provides basic information for small quantity hazardous waste generators and links directly to the appropriate government web pages for the corresponding regulations.

Are You a Small Quantity Generator (SQG)?

If you generate less than 2200 pounds (1000 kilograms) but more than 220 pounds (100 kilograms) of hazardous waste per calendar month, you are considered a small quantity generator (SQG) for that month.

What are the SQG requirements?

Generation and Disposal: As a SQG, you are allowed to generate less than 2200 pounds of hazardous waste in any calendar month. All hazardous waste generated by the SQG that is not treated onsite must be manifested to an offsite treatment, storage and disposal facility (TSDF) permitted to handle hazardous waste or to an approved designated facility (e.g., recycling facility). For the regulations about identifying hazardous waste, see 40 CFR 261 [Adobe Acrobat PDF File].

Documentation and Reporting:

Manifests: Hazardous waste that is sent to a TSDF or an approved designated facility must be listed on a Uniform Hazardous Waste Manifest. A manifest provides a description of the hazards of the waste and the waste handlers. You must sign and date the manifest and obtain the signature of the transporter on the manifest. You must also keep this copy of the form until you receive a copy signed by the TSDF. Manifests must be kept for at least 3 years from the date of shipment. If your generator status changes, you must notify EPA.

Land Disposal Restriction: Many types of hazardous waste are restricted from being disposed in or on the land due to the probability of groundwater or soil contamination. The manifest for these wastes must be accompanied by a Land Disposal Restriction (LDR) notification. The LDR is a one-time notification form that is signed by you, the generator, and indicates that you understand this waste cannot be land disposed. According to federal regulations, it is the responsibility of the generator to provide the manifest and the LDR. Most hazardous waste disposal contractors will supply one or both of these forms for you.

Exception Report: Once a hazardous waste manifest has been signed and dated by you (the generator), EPA gives the disposal contractor 60 days to transport the waste to the TSDF and return a signed copy of the manifest to you. If, after 60 days, you do not receive the "Return to Generator" copy of the manifest signed by the TSDF, you must send a legible photocopy of the manifest to the EPA Regional Administrator and a brief written statement about not receiving the signed copy. This report must be maintained for at least 3 years.

Miscellaneous: Generators are also required to keep records of test results, waste analyses, or other waste determinations for at least 3 years from the date of shipment of that waste.

Storage/containers: You can store hazardous waste in tanks or containers, provided they are not leaking, bulging, rusted, or incompatible with the waste stored in them (e.g., certain types of acid in metal containers) (40 CFR Part 262.34). Storage areas should have a means of secondary containment, an alarm, a fire extinguisher, a "No Smoking" sign, and a means of communication (e.g., walkie-talkie, cellular phone, or air horn) in the event of a spill or other emergency.

Labeling: Hazardous waste tanks and containers must be labeled with the words "Hazardous Waste", the contents of the container, the accumulation start date, the waste codes of the contents, and the EPA ID number of the generator. A standard yellow hazardous waste label can usually be obtained through your EPA or State office, or through some catalogs.

Storage/time limitations: SQGs are required to dispose their hazardous waste within 180 days of placing the waste into the container. The exception to this is if the facility elects to "satellite" its waste first. If you satellite your waste, you must collect it in a container "at or near the point of generation." The interpretation of "at or near" varies from state to state but generally means the container cannot be separated by a door or wall from the point of generation and cannot be more than 50 feet from the point of generation. The container must be labeled only with its contents. Most states allow satellite generation of up to 55 gallons of one type of waste. Once the 55-gallon limit has been reached, the waste must be moved to an onsite accumulation area or building where it can be stored for up to 180 days from that time.

Note about Episodic Generators: Depending on your type of business, you might be regulated under different rules at different times. If, in June, you generate between 220 and 2,200 lbs (100 kg to 1,000 kg) of hazardous waste, you would be considered an SQG for June and your waste would then be subject to the management requirements for SQGs. If, for example, you generate less than 220 lbs (100 kg) of hazardous waste during the month of June, your generator status would change and you would be considered a CESQG for June. Your June waste would be subject to the hazardous waste management requirements for CESQGs.

Additional Information

Contacts:

bulletGeneral information regarding the EPA bulletRCRA Hotline at 1-800-424-9346.

Publications:

bulletHazardous Waste: The Conditionally Exempt Small Quantity Generator Fact Sheet bulletHazardous Waste: The Large Quantity Generator Fact Sheet bulletHazardous Waste: Determining Your Generator Status Fact Sheet bulletIdentifying Hazardous Waste Fact Sheet bulletHow Do I Dispose of Waste Containers? Fact Sheet bulletHazardous Waste Contingency Planning and Notification Fact Sheet bulletDo I Need a Hazardous Waste Generator Identification Number? Fact Sheet bulletUnderstanding the Hazardous Waste Rules: A Handbook for Small Businesses -- 1996 Update EPA 530-K-95-001, June 1996bulletAgency Information Collection Activities: Proposed Collection; Comment Request; Criteria for Classification of Solid Waste Disposal Facilities and Practices, Recordkeeping and Reporting Requirements (Renewal); Notice of Request for Renewal bulletHazardous Waste Manifests, Manifest Preparation and Shipping bulletRCRA in Focus: Photo Processing - March, 1999
Adobe Acrobat PDF File (697K) || About...(3K)
bulletRCRA in Focus: Printing - February, 1998
Adobe Acrobat PDF File (245K) || ASCII Text File (53K) || About...
bulletConditionally Exempt Small Quantity Generator Rule - June 1996. bulletRCRA Hotline Training Modules - "Introduction to Generators"
Adobe Acrobat PDF File || ASCII Text File
bulletRCRIS RCRA Regulated Handlers bulletResources on Waste for Businesses and Governments
Adobe Acrobat PDF File [315 K] || ASCII Text File [48 K] || About...
bulletUnderstanding the Hazardous Waste Rules: A handbook for Small Businesses

 

This page was updated on 30-Mar-2016