How to Determine Your Site's Hazardous Waste Generator Status [40 CFR 262.13]

February 08, 2018

 

According to 40 CFR 262.13, hazardous waste generators must determine their generator status (also called generator category) on a calendar month basis, and manage their hazardous waste according to their generator status at the time the waste was generated.

The regulations for how you must manage hazardous waste on-site are based on your generator status.

In November 2016, the EPA published the Hazardous Waste Generator Improvements Rule which changed how you must determine your generator status. Below is the EPA’s generator category determination table along with an explanation.

Generator Categories Based on Quantity of
Hazardous Waste Generated in a Calendar Month
(40 CFR 262.13)

Acute Hazardous Waste
(P-listed waste and F020-F023, F026-F027)

Non-Acute Hazardous Waste

Clean-Up Residues of Acute Hazardous Waste
(P-listed waste and F020-F023, F026-F027)

Generator Category

New Regulatory Reference

> 1 kg

Any amount

Any amount

LQG

40 CFR 262.17

Any amount

≥ 1,000 kg

Any amount

LQG

40 CFR 262.17

Any amount

Any amount

> 100 kg

LQG

40 CFR 262.17

≤ 1 kg

> 100 kg < 1,000 kg

≤ 100 kg

SQG

40 CFR 262.16

≤ 1 kg

≤ 100 kg

≤ 100 kg

VSQG

40 CFR 262.14

 

As the table shows, your site would be a:

  • Very small quantity generator (VSQG) if in a calendar month you generate less than 1 kg (2.2 lb) of acute hazardous waste, less than 100 kg (220 lb) of regular hazardous waste, and less than 100 kg of acute spill debris
  • Small quantity generator (SQG) if in a calendar month you exceed the VSQG amounts but generate less than or equal to 1 kg acute hazardous waste, less than or equal to 100 kg of acute hazardous waste spill debris, and less than 1,000 kg of non-acute hazardous waste
  • Large quantity generator (LQG) if in a calendar month your site exceeds 1 kg of acute, 100 kg of acute spill debris, or 1,000 kg of non-acute hazardous waste

 

In the March 24, 1986, Federal Register (51 FR 10153), EPA reiterated that generator status is determined monthly for generators who do not generate hazardous waste at a uniform rate, and that you must manage your hazardous waste according to your generator status in a particular month. If your site is a VSQG or SQG, and you have a one-time event that increases your generator status, this is called episodic generation and you may be able to keep your current status if you meet certain conditions.

Learn more about how to comply with the latest hazardous waste management regulations by attending Environmental Resource Center’s Hazardous Waste Management (RCRA): The Complete Course seminar, Hazardous Waste Management: The Complete Course – Webcast, or Hazardous Waste Management: Annual Update – Webcast.

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Annual hazardous waste training is required for anyone who generates, accumulates, stores, transports, or treats hazardous waste. Learn how to manage your hazardous waste in accordance with the latest state and federal regulations. This course fulfills your RCRA initial training requirements.

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