United States
Environmental Protection
Ac,ency
March 1985
EPA/530-SW-85-006
v°/EPA Requirements for
Small Quantity
Hazardous Waste
Generators
Questions and
Answers
Environmental Protection Agency
-•n V, Library
South Dearborn Street
t.go, Illinois 60604
U.S. Environmental Protection Agency
Region V, Library
230 South Dearborn Street
Chicago, Illinois 60604
US GOVERNMENT PRINTING OFFICE 1985—556-511/8690
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—EPA's RCRA Hotline: 800-424-9346 (382-3000 in
the Washington, DC, area)
—EPA's Small Business Hotline: 800-368-5888
—EPA Regional Offices (see list beloxv)
—national or regional trade associations
In ALL cases, generators should contact their
state agency responsible for hazardous waste
management for information on state requirements.
Q.How can generators obtain copies of the Uniform
Manifest?
A. Small quantity generators should first check with
their state agency responsible for hazardous waste
management since 22 states require use of their
own versions of the Uniform Manifest and may
require additional information, such as generator
identification numbers or the name of the waste
hauler. EPA regional offices (see list below) may be
able to assist small quantity generators in obtaining
the proper manifest form. If no state manifest is
required, the manifest may be photocopied from
the Federal Register of March 20, 1984, or
purchased from some commercial printers.
Q.What requirements do states impose on small
quantity generators?
A.State requirements may be stricter than federal
requirements for small quantity generators. Eor
example, 15 states (California, Illinois, Kansas,
Louisiana, Maine, Maryland, Massachusetts,
Minnesota, Missouri, New Hampshire, New jersey,
Rhode Island, South Carolina, Vermont, and
Washington) already require generators of under
1,000 kilograms per calendar month to manifest
their waste and ship it only to authorized
hazardous waste management facilities. Four states
(California, Louisiana, Minnesota, and Rhode
Island) have no small quantity generator
exemptions and, therefore, currently regulate all
generators of hazardous waste. Other states have
differing exclusion levels. Firms that think they
may be generators of hazardous waste are strongly
encouraged to contact their state hazardous waste
management agency for information on the
requirements.
Q.Where can small quantity generators get further
information or assistance?
A. Generators should contact their state hazardous
waste offices for information on requirements they
must meet.
For questions on the RCRA amendments or
federal hazardous waste regulations in general,
generators may contact their EPA regional office,
(see list below) or EPA's toll-free RCRA Hotline,
800-424-9346: in Washington, DC, 382-3000. Small
quantity generators may also wish to contact EPA's
Small Business Hotline: 800-368-5888.
EPA Regional Offices
EPA Region 1
JFK Federal Building
Boston, MA 02203
(617)223-7210
Connecticut, Massachusetts,
Maine, New Hampshire,
Rhode Island, Vermont
EPA Region 2
26 Federal Plaza
New York NY 10007
(212) 264-2525
New Jersey, New York,
Puerto Rico, Virgin Islands
EPA Region 3
841 Chestnut Street
Phidelphia PA 19107
(215) 597-9800
Delaware, Maryland,
Pennsylvania, Virginia,
West Virginia, District of Columbia
EPA Region 4
345 Courtland Street NE
Atlanta, GA 30365
(404)881-4727
Alabama, Florida, Georgia,
Kentucky, Mississippi,
North Carolina, South
Carolina, Tennessee
EPA Region 5
230 South Dearborn Street
Chicago, IL 60604
(312) 353-2000
Illinois, Indiana,
Michigan, Minnesota,
Ohio, Wisconsin
EPA Region 6
1201 Elm Street
Dallas, TX 75270
(214) 767-9885
Arkansas, Louisiana,
New Mexico, Oklahoma,
Texas
EPA Region 7
726 Minnesota Avenue
Kansas City, KA 66101
(913) 236-2800
Iowa, Kansas, Missour,,
Nebraska
EPA Region 8
1860 Lincoln Street
Denver, CO 80295
(303) 837-3895
Colorada, Montana,
North Dakota, South
Dakota, Utah, Wyoming
EPA Region 9
215 Freemont Street
San Francisco, CA 94105
(415) 974-8153
Arizona, California, Hawaii,
Nevada, American Samoa, Guam,
Trust Territories of the Pacific
EPA Region 10
1200 Sixth Avenue
Seattle, WA 98101
(206) 442 1260
Alaska, Idaho, Oregon,
Washington
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Manifest to accompany hazardous waste they ship
off their premises. The Manifest is a specific form
EPA requires all regulated hazardous waste
generators to use when they ship hazardous waste.
Use of the Manifest also satisfies Department of
Transportation (DOT) requirements for shipment of
hazardous materials.
As of August 5, 1985, affected small quantity
generators will be required to complete the
following information on the Manifest:
—name, address, and signature of the generator
—DOT shipping name, hazard class, and waste
identification number
—number and type of containers
—quantity of hazardous waste being transported
—name and address of facility designated to
receive the hazardous waste.
Q.What if EPA does not promulgate final regulations
by the March 31, 1986, deadline?
A,The 1984 amendments include a number of
provisions that will automatically become effective
April 1, 1986, if EPA does not publish final rules
before that date:
• Generators of 100 to 1,000 kilograms of waste
per calendar month must continue to complete the
Uniform Manifest and include the name of the
waste transporter in addition to the other
information required.
• Treatment, storage, and disposal of waste
produced by these generators must occur at a
"Subtitle C facility"—that is, a facility authorized
under Subtitle C by EPA or a state to treat, store, or
dispose of hazardous waste.
• A copy of each manifest must be signed by the
facility designated to receive the waste, and
returned to the generator, who must keep it on file
for 3 years.
• Manifest Exception Reports must be filed with
EPA twice a year. A generator who has not
received a signed copy of the Uniform Manifest
from the designated facility confirming its receipt
of a waste shipment must list such "lost
shipments" on the manifest Exception Report.
These provisions do not necessarily reflect the
standards that EPA is required to develop for small
quantity generators under the 1984 amendments.
Those regulations will be proposed in the Federal
Register in the summer of 1985.
Q.Do provisions taking effect August 5, 1985, require
the use of approved hazardous waste transporters
or disposal facilities by affected small quantity
generators?
A. No. The August 1985 requirement for these
generators to complete parts of the Uniform
Hazardous Waste Manifest still allows them to
send wastes to either an authorized hazardous
waste facility or to a facility approved by the state
to manage nonhazardous solid waste, such as a
sanitary landfill. In reality, however, small
quantity generators may find that only hazardous
waste transporters and hazardous waste facilities
are willing to accept waste that is accompanied by
a Manifest. If this is the case, state hazardous
waste offices should be able to provide lists of
licensed transporters and hazardous waste facilities
to help small quantity generators locate these
services.
By March 31, 1986, or by the date that new
regulations issued by EPA become effective, small
quantity generators will be required to treat, store,
or dispose of'their hazardous waste at an
authorized hazardous waste (Subtitle C) facility.
(Certain wastes, principally used lead-acid
batteries, will continue to remain exempt from
most RCRA requirements if they are recycled.)
Q.How can small quantity generators determine if
they produce the kinds or quantities of waste that
make them subject to the 1984 amendments?
A. Generators must first determine whether they
produce hazardous waste. EPA considers a waste
hazardous if (1) it has any one of four
characteristics (ignitability, reactivity, corrosivity,
toxicity) that make it dangerous to human health
and the environment after it is discarded; or (2) it
is listed among the approximately 400 substances
EPA has determined to be hazardous.
EPA's hazardous waste regulations are explained
in detail in the Code of Federal Regulations (CFR)
at 40 CFR Parts 260-266. If the Code of Federal
Regulations is not available for reference, contact
one or more of the following for information:
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In 1976, Congress enacted the Resource
Conservation and Recovery Act (RCRA) to protect
human health and the environment from improper
waste management practices. In issuing hazardous
waste regulations under RCRA, the Environmental
Protection Agency (EPA) first focused on those
large generators who produce the greatest portion
of the hazardous waste. Regulations EPA published
on May 19, 1980, exempted "small quantity
generators" from most of the hazardous waste
requirements. But amendments to RCRA signed
into law November 8, 1984, mandate several new
requirements for small quantity generators. Here
are answers to basic questions arising as a result of
the 1984 amendments.
Q. What is a small quantity generator?
A. A "small quantity generator" is a business or
organization that produces hazardous waste in
quantities less than 1,000 kilograms (approximately
2,200 pounds) per calendar month. There are
600,000 to 650,000 such establishments currently
operating in the United States.
Q. Are all small quantity generators affected by the
new law?
A. No. The new law will initially affect about
175,000 generators who produce 100 to 1000
kilograms of hazardous waste per month.
Generators who produce less than 100 kilograms
per month will not be immediately affected by the
amendments.
Q.How much hazardous waste is produced by small
quantity generators?
A. Altogether, generators of less than 1000 kilograms
per month produce about 940,000 metric tons of
hazardous waste per year. Generators affected by
the new law account for an estimated 700,000
metric tons per year.
Q. What kinds of businesses are likely to be small
quantity generators?
A.An EPA survey indicated that nearly 85 percent of
the small quantity generators are in
nonmanufacturing industries. Vehicle maintenance
and construction establishments are the largest
U<6. Environmental "-• tr .-:~n Agency
categories covered. Other nonmanufacturing
establishments affected include laundries and dry
cleaners, photographic processors, equipment
repair shops, laboratories, and schools. The other
15 percent of small quantity generators are in
manufacturing: primarily metal manufacturing, but
also including printing, chemical manufacturing
and formulating, furniture manufacturing, and
textile manufacturing establishments.
This information is based on a survey conducted
by EPA. The survey covered 22 industry categories
that were likely to contain a significant number of
small quantity generators. EPA estimates that
approximately two-thirds of all small quantity
generators fall into these 22 industry groups.
Q.What kinds of waste do small quantity generators
produce?
A.Some of the most common wastes produced by
small quantity generators are:
—spent solvents and chemicals
—chemical wastes produced during manufacturing
or industrial processes
—discarded chemical products
—chemical containers and chemical spill residues
—used lead-acid batteries.
Q. How have requirements for small quantity
generators changed?
A. Under the May 1980 hazardous waste regulations,
small quantity generators have been required only
to determine whether or not they produce
hazardous waste, and to see that the waste is sent
to facilities approved by EPA or a state to manage
solid or hazardous waste.
In the 1984 amendments to RCRA, however,
Congress directed EPA to publish by March 31,
1986, regulations covering generators of more than
100 but less than 1,000 kilograms of hazardous
waste per month. In these regulations, EPA must,
at a minimum, require these small quantity
generators to see that their hazardous waste is
managed at an approved hazardous waste facility.
The new law also specifies that by August 5,
1985, generators of 100 to 1,000 kilograms of
hazardous waste per month will be required to
complete parts of the Uniform Hazardous Waste
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