Hazardous Waste Management

Under the RCRA, hazardous waste generators (40 CFR Part 261 and 262) are the first link in the cradle-to-grave hazardous waste management system.1-3 Because various types of facilities generate different quantities of wastes resulting in varying degrees of risk to human health and the environment, the degree of regulation to which each generator is subjected to depends on how much waste each generator produces every calendar month (Box B).

Box B. Categories of hazardous waste generators.1-3
Categories of hazardous waste generatorsDefinitions of hazardous waste generator categoriesRegulatory requirement
Large quantity generators (LQG)Facilities that generate:
  • 1,000 kg or more of hazardous waste per calendar month (approximately 2,200 lbs.)
    or
  • 1 kg or more of acutely hazardous waste per calendar month (approximately 2.2 lbs.)
LQGs and SQGs must:
  • Identify whether their solid waste is a hazardous waste, and if so, determine the quantity of hazardous waste generated in a calendar month to establish its generator category
  • Obtain an EPA ID number
  • Comply with accumulation and storage requirements (including requirements for training and emergency arrangements)
  • Prepare the hazardous waste for transportation
  • Track the shipment and receipt of such waste
  • Meet recordkeeping and reporting requirements
Small quantity generators (SQG)Facilities that generate:
  • Greater than 100 kg (approximately 220 lbs.) but less than 1,000 kg of hazardous waste per calendar month
    and
  • Accumulate on-site 6,000 kg or less (approximately 13,200 lbs.) of hazardous waste at any time
Conditionally exempt small quantity generators (CESQG)Facilities that generate:
  • 100 kg or less of hazardous waste per calendar month
    or
  • 1 kg or less of acutely hazardous waste per calendar month.
CESQGs must:
  • Identify whether their solid waste is a hazardous waste, and if so, determine the quantity of hazardous waste generated in a calendar month to establish its generator category
  • Comply with waste accumulation quantity limit requirement
    • May not accumulate or store more than 1,000 kg of hazardous waste
  • Accumulate hazardous wastes in containers in a manner that prevents its release into the environment
  • Deliver their own hazardous waste in their own vehicle or have an approved hazardous waste transporter deliver it to an approved hazardous waste management facility:
    • Permitted or interim status hazardous waste treatment, storage, and disposal facility (TSDF)
    • State hazardous waste facility
    • Municipal solid waste landfill (MSWLF)
    • Recycling facility
    • Universal waste facility (see Universal Waste Management section)