Hazardous Waste Generator Status

What is hazardous waste generator status?

Under the Resource Conservation and Recovery Act (RCRA), any facility that produces hazardous waste is classified into a generator status that dictates the scope of its regulatory requirements. Generator statuses are determined by the volume of hazardous waste generated within a calendar month. The three categories include:

1. 1. Very Small Quantity Generator (VSQG)
   2. Small Quantity Generator (SQG)
   3. Large Quantity Generator (LQG)

Proper classification is essential for compliance with hazardous waste permitting and adhering to RCRA regulations. The following sections in this page breakdowns classifications and each generator category.

Waste Characterization Process

Before determining a facility’s generator status, it must first characterize the waste produced to confirm whether it is subject to hazardous waste regulations. The characterization follows:

1. 1. Determine whether material is solid waste, which includes materials that are:
      1. Abandoned
      2. Inherently waste-like
      3. Military munitions
      4. Recycled in certain manner
   2. Determine whether waste is excluded from solid waste regulations (i.e. RCRA exemptions)
      1. Examples: solvent-contaminated wipes, certain petroleum products, or gasoline
      2. Refer to SEC’s RCRA for exemption details
   3. Determine the point of generation to assess if waste is hazardous
   4. Determine classification of hazardous waste
      1. Characteristic Waste Codes (D Codes) – These wastes exhibit one or more hazardous characteristics as defined under 40 CFR Part 261 Subpart C.
         1. Ignitability (D001)
         2. Corrosivity (D002)
         3. Reactivity (D003)
         4. Toxicity (D004-D043)
         5. Note: Some “D” codes also apply to specific listed wastes that exhibit one or more hazardous characteristics, as identified under 40 CFR Part 261 Subpart D.
      2. Listed Waste – Based on where they came from (industry or process)
         1. “F” Codes – Waste from Non-Specific Sources (e.g. solvents, degreasers, etc.)
         2. “K” Codes – Wastes from specific sources (e.g. petroleum refining, pesticide, etc.)
         3. “P” Codes – Acutely Hazardous Compounds
         4. “U” Codes – Toxic Compounds List
         5. Other Codes – LABP (Lab Pack), PHRM (Hazardous Waste Pharmaceuticals)
   5. Deterine the generator status based upon the amount of hazardous waste generated a. Very Small Quantity Generator (VSQG)
      1. Small Quantity Generator (SQG)
      2. Large Quantity Generator (LQG)

Regulatory Guidance for Hazardous Waste Generators

Once waste is determined to be hazardous, the facility’s generator status is evaluated based on monthly production volumes. The classifications determine applicable regulatory responsibilities under 40 CFR Part 262.

1. 1. VSQG – §262.14
      1. Generation: Less than 100 kg (220 lb) of hazardous waste generation and less than 1 kg (2.2 lb) of acute hazardous waste generation per calendar month
      2. Storage: Less than 1,000 kg (2,200 lb) of hazardous waste storage and less than 1 kg (2.2 lb) of acute hazardous waste storage at any one time
      3. Time Limit: No accumulation time limit
   2. SQG- §262.16
      1. Generation: Between 100 kg (220 lb) and 1,000 kg (2,220 lb) of hazardous waste generation and less than 1 kg (2.2 lb) of acute hazardous waste generation per calendar month
      2. Storage: Between 1,000 kg (2,200 lb) and 6,000 kg (13,200 lb) of hazardous waste storage and less than 1 kg (2.2 lb) of acute hazardous waste storage at any one time
      3. Time Limit: Accumulate hazardous waste on-site for 180 days without permit (or 270 days if shipping distance greater than 200 miles)
   3. LQG – §262.17
      1. Generation: More than 1,000 kg (2,200 lbs) of hazardous waste generation or more than 1 kg (2.2 lb) of acute hazardous waste generation per calendar month
      2. Storage: Exceeds 6,000 kg (13,200 lbs) of hazardous waste storage or 1 kg (2.2 lb) of acute hazardous waste storage at any one time
      3. Time Limit: Accumulate waste on-site for 90 days

The following tables help distinguishment generator status based upon generation of acute and/or non-acute hazardous waste:

Hazardous Waste Episodic Generation Rule

Facilities classified as VSQG or SQG may occasionally experience non-routine events that temporarily increase their hazardous waste generation above their typical thresholds. To accommodate these exceptions, the EPA established the Hazardous Waste Episodic Generation Rule under 40 CFR Part 262 Subpart L. Key provisions include:

• • Allows one episodic event per calendar year (planned or unplanned)
  • Must notify the EPA using Form 8700-12
  • Planned Event – 30 days prior to event
    • Unplanned Event – Within 72 hours of event
    • Facility must obtain an EPA identification Number
  • All waste must be managed and removed within 60 days

Note: This rule has not been adopted by all states.

Key Compliance & Waste Management

Proper hazardous waste management involves more than classification. It requires a comprehensive system of control, documentation, and oversight. Facilities must adhere to RCRA standards to ensure accurate and safe handling, storage, and transportation of waste. Our SEC team provides streamlined services to help facilities implement robust compliance programs tailored to their generator status.