How to Manage Episodic Hazardous Waste [40 CFR 262]

February 15, 2018

How to Manage Episodic Hazardous Waste [40 CFR 262]

If your site is normally a very small quantity generator (VSQG) or a small quantity generator (SQG) of hazardous waste, you know that if you generate more that your category’s monthly limits, your site could be elevated to the next higher generator category. For information about the monthly limits, see Environmental Resource Center’s February 8, 2018, Reg of the Day™ on hazardous waste generator status.

Now, there’s a new option that could allow you to keep your prior generator status, if you have a one-time event that causes you to exceed your category’s threshold. EPA’s Hazardous Waste Generator Improvements Rule created a new 40 CFR 262, Subpart L, which establishes criteria for episodic generation of hazardous waste that will allow you to keep your initial generator status. An episodic event can be a planned event, like a chemical clean out, or an unplanned event, such as a spill.

Many of the episodic waste requirements are the same for SQGs and VSQGs that exceed their limits, but there are a few requirements that differ. SQGs and VSQGs must notify the EPA or their state at least 30 days prior to a planned event, and within 72 hours of an unplanned event. If the VSQG does not already have an EPA identification number, then one must be obtained per the notification requirements at 40 CFR 262.18.

Episodic hazardous waste may be accumulated in containers or tanks that are labeled with the words “episodic hazardous waste” and an indication of the hazards, as well as the date the episodic event began. When managing episodic waste in tanks, you may document the time limit using methods such as inventory logs or monitoring equipment. The date is required because regardless of your generator status or event type, the episodic waste must be shipped off-site using a hazardous waste manifest within 60 days from the start of the event.

You must keep the following records for at least three years:

  • Beginning and end dates of the episodic event
  • Description of the event
  • Types and quantities of episodic hazardous waste
  • Description of how the hazardous waste was managed and the name of the RCRA-designated facility that received the hazardous waste
  • Name(s) of the transporters
  • An approval letter if a generator petitioned for a second event in the calendar year


The container and tank management rules for SQGs and VSQGs differ, as summarized below.

VSQG requirements:

  • Containers and tanks must be in good condition and compatible with the waste
  • Containers must be kept closed unless waste is being added or removed
  • When episodic waste is stored in tanks, there must be procedures in place to prevent overflow, and the tanks must be inspected daily


SQG requirements:

  • Containers must be in good condition, compatible with the waste, closed, and inspected weekly
  • Hazardous wastes must be compatible with other wastes, residues, or materials that they are stored with; otherwise, they must be separated or protected by means such as dikes, berms, walls, or other devices
  • Nothing may be placed in a tank that could cause the tank to rupture, corrode, or leak
  • Uncovered tanks must have at least 2 feet of freeboard—the distance from the waste level to the top of the tank—unless the tank is equipped with a containment structure
  • If waste is continuously fed into a tank, the tank must be equipped with a means to stop the inflow
  • Discharge control equipment, monitoring equipment, and waste levels must be inspected daily, and construction materials and surrounding areas must be inspected weekly


SQGs with ignitable or reactive wastes must take precautions to ensure wastes do not ignite or react.

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.

Highest Rated RCRA Hazardous Waste Management Training

Environmental Resource Center has provided the highest quality Hazardous Waste Management Training for over 25 years. Our instructors bring a wide range of practical experience to the classroom, conducting seminars and live webcasts with expert knowledge, interactive exercises and a fun, relaxed atmosphere. RCRA Hazardous Waste Management classes are available as public seminars, instructor-led webcasts, self-paced online courses, and as customized on-site sessions designed to meet your company’s individual needs.

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February 27-March 1

Charlotte – Hazardous Waste and DOT Training
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February 27, March 26-28

Houston – Texas Hazardous Waste Management and DOT Training
March 6-8

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March 13-14

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March 19-22

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March 27-29

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April 3-5

Special offers for Reg of the Day™ readers: Register for any of the classes listed above and you can take advantage of offers 1 and 2 or 1 and 3.

1.  Register two attendees at full price and each additional person attends the same class for half price.
2.  Save $100 off your registration when you register for both Hazardous Waste and DOT training in the same city.
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Upcoming Hazardous Waste Management Webcasts

Environmental Resource Center’s live instructor-led webcast training is the best way to get the training you need—without leaving your office. Stay up-to-date with the latest regulations that can impact your facility and get your site-specific questions answered by our experienced, expert instructors.

Hazardous Waste Management: The Complete Course – Webcast|
March 13

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.

Hazardous Waste Annual Update – Webcast
February 20, March 20

If you have had prior RCRA training, you can meet your annual mandatory RCRA update training requirements in this live, online session that’s designed to meet your 40 CFR 265.16 training requirements.

California Hazardous Waste Management – Webcast
February 28

Attend this live, interactive online course to learn how to comply with the latest requirements for the management of hazardous waste in California. This course meets both the California and federal initial and annual training requirements for generators of hazardous waste.

EPA’s New Hazardous Waste Generator Improvements Rule – Webcast
March 9

EPA recently enacted the biggest changes in the hazardous waste generator rules in over 30 years. Attend Environmental Resource Center’s live web-based training to learn how to comply with over 60 changes and new requirements established by the Hazardous Waste Generator Improvements Rule.

Hazardous Waste Manifest Training – Webcast
February 16

When hazardous waste is shipped from your site, it must be accompanied by a hazardous waste manifest. Even if your waste transporter fills out the manifest, you are responsible for the portions of the manifest that they complete on your behalf. This live online training is designed to satisfy the training requirements for anyone who completes or signs hazardous waste manifests.

Webcast special offer:

  • Register two attendees at full price and each additional person attends the same class for half price.


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Learn when it’s convenient for you. Environmental Resource Center’s self-paced online training makes it easy to learn how to comply with the latest regulations that can impact your facility, and meet your training requirements in our no-sweat online courses:


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All of Environmental Resource Center’s top-rated training can be customized for your site. Site-specific training is an efficient and economical way to train your employees, reducing time away from the job and travel costs.

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