Hazardous Waste: Determining Your Generator Status

The Office of Compliance Fact Sheet Series

Updated March 1998 - Doc. No. 1201

What is Hazardous Waste Generator Status?

If your operations cause hazardous waste to be generated, you must determine your generator status. The hazardous waste generator status of a facility is determined based on the amount of hazardous waste generated in any given month of the calendar year. Hazardous waste generators are divided into three categories: conditionally exempt small quantity generators, small quantity generators, and large quantity generators.

Conditionally Exempt Small Quantity Generator (CESQG): If you generate 220 pounds (100 kilograms) or less of hazardous waste per month, you are considered a CESQG. Some state hazardous waste management regulations do not recognize this generator status.

Small Quantity Generator (SQG): If you generate more than 220 pounds (100 kilograms) but less than 2200 pounds (1000 kilograms) of hazardous waste per month, you are considered an SQG for that year.

Large Quantity Generator (LQG): If you generate 2200 pounds (1000 kilograms) or more of hazardous waste in per month of the calendar year, you are considered an LQG for that year.

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

How do I Determine my Hazardous Waste Generator Status?

To determine which generator status applies to your facility, you must count all quantities of hazardous waste that are:

Generated and collected at your facility prior to treatment or disposal.

Packaged and transported offsite. [Note: If you are a SQG and transport wastes in bulk, the quantity of accumulated waste shipped may total over 1000 kg, as long as total hazardous waste generated per month is less than 1000 kg.]

• Placed directly in a regulated treatment or disposal unit at your place of business.
• Generated as still bottoms or sludge and removed from product storage tanks.

You do NOT have to count wastes that:

Are left on the bottom of the solvent containers that have been emptied by all commonly used means (e.g., pouring or pumping) and where no more than 2.5 cm (1 inch) of residue remains in the bottom of the container or no more than 3% by weight of the total capacity of the container remains in the container if it is less than or equal to 110 gallons in size or no more than 0.3 % by weight of the total capacity of the container remains in the container if it is greater than 110 gallons in size.

Are left as residue at the bottom of storage tanks, if the residue is not removed (i.e., residues left in the bottom of the storage container are not counted as long as they are not removed when the tank is refilled).

Are reclaimed continuously onsite without storing the waste prior to reclamation.

Have already been counted once during the calendar month, and treated onsite or reclaimed in some manner and used again.

Are directly discharged to a municipal treatment plant or publicly owned treatment works (POTW) without being stored or accumulated first. This discharge to a POTW must comply with the Clean Water Act and any local POTW regulations.

Additional rules to keep in mind when determining your hazardous waste generators status are:

• Used oil and used diesel fuel are not considered as part of the hazardous waste generation unless they are contaminated with a hazardous waste or your state regulations consider them to be a hazardous waste.
• Hazardous wastes that are to be recycled must be managed as hazardous wastes until the point of recycling; however, it is not necessary to consider these in your monthly generation rates.
• Most states have additional hazardous waste regulations that you must also follow. Be sure to check with your state environmental office for additional, and in some cases, more stringent requirements.

• Contact your state to determine whether multiple facilities generating hazardous waste that are located on the same parcel are considered one generator.

Contacts:

General information regarding EPA - http://www.epa.gov

RCRA Hotline 1-800-424-9346.