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Categories of Hazardous Waste Generators

A generator is any person who produces a hazardous waste as listed or characterized in part 261 of title 40 of the Code of Federal Regulations (CFR). Recognizing that generators produce waste in different quantities, EPA established three categories of generators in the regulations:

  • very small quantity generators,
  • small quantity generators, and
  • large quantity generators.

The volume of hazardous waste each generator produces in a calendar month determines which regulations apply to that generator. Below is more information about each category of generator.

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Very Small Quantity Generators (VSQGs)

Very Small Quantity Generators (VSQGs) generate 100 kilograms or less per month of hazardous waste or one kilogram or less per month of acutely hazardous waste. Requirements for VSQGs include:

  • VSQGs must identify all the hazardous waste generated.
  • VSQGs may not accumulate more than 1,000 kilograms of hazardous waste at any time.
  • VSQGs must ensure that hazardous waste is delivered to a person or facility who is authorized to manage it.

See 40 CFR §262.14 for a complete description of the VSQG regulations.

Additionally, most states are authorized to implement the RCRA program. State generator categories can be different than the federal categories. Please see the differences in hazardous waste generator categories table.

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Small Quantity Generators (SQGs)

Small Quantity Generators (SQGs) generate more than 100 kilograms, but less than 1,000 kilograms of hazardous waste per month. Major requirements for SQGs include:

  • SQGs may accumulate hazardous waste on-site for 180 days without a permit (or 270 days if shipping a distance greater than 200 miles).
  • The quantity of hazardous on-site waste must never exceed 6,000 kilograms.
  • SQGs must comply with the hazardous waste manifest requirements at 40 CFR part 262, subpart B and the pre-transport requirements at 40 CFR §§262.30 through 262.33.
  • SQGs must manage hazardous waste in tanks or containers subject to the requirements found at 40 CFR §§262.16(b)(2) and (3).
  • SQGs must comply with the preparedness and prevention requirements at 40 CFR §§262.16(b)(8) and (9), and the land disposal restriction requirements at 40 CFR part 268.
  • There must always be at least one employee available to respond to an emergency. This employee is the emergency coordinator responsible for coordinating all emergency response measures. SQGs are not required to have detailed, written contingency plans.

See 40 CFR part 262 for a complete description of the SQG regulations.

Most states are authorized to implement the RCRA program. The quantity limits for state generation categories can be different than the federal limits. Please see the differences in hazardous waste generator categories table.

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Large Quantity Generators (LQGs)

Large Quantity Generators (LQGs) generate 1,000 kilograms per month or more of hazardous waste or more than one kilogram per month of acutely hazardous waste. Major requirements for LQGs include:

  • LQGs may only accumulate waste on-site for 90 days. Certain exceptions apply.
  • LQGs do not have a limit on the amount of hazardous waste accumulated on-site.
  • Hazardous waste generated must be managed in tanks, containers, drip pads or containment buildings subject to the requirements found at 40 CFR §§ 262.17(a)(1)-(4) and, specifically for drip pads and containment buildings, 40 CFR part 265, subparts W and DD, respectively.
  • LQGs must comply with the hazardous waste manifest requirements at 40 CFR part 262 subpart B and the pre-transport requirements at 40 CFR §§262.30 through 262.33.
  • LQGs must comply with the preparedness, prevention and emergency procedure requirements at 40 CFR part 262 subpart M and the land disposal restriction requirements at 40 CFR part 268.
  • LQGs must submit a biennial hazardous waste report.

See 40 CFR part 262 for a complete description of the LQG regulations.

Additionally, most states are authorized to implement the RCRA program. The quantity limits for state generation categories can be different than the federal limits. Please see the differences in hazardous waste generator categories table.

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