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Hazardous Waste:The Small
Quantity Generator
Do I QUALIFY As A SMALL QUANTITY GENERATOR (SQG)?
If you generate less than 2200 pounds (1000 kilograms) but more than 220 pounds (100 kilograms) of
hazardous waste per calendar month, you are considered a small quantity generator (SQG) for that
month.
WHAT ARE MY REQUIREMENTS AS A SQG?
Generation and Disposal: As a SQG, you are allowed to generate less than 2200 pounds of hazardous
waste in any calendar month. All hazardous waste generated by the SQG that is not treated onsite must
be manifested to an offsite treatment, storage and disposal facility (TSDF) permitted to handle hazardous
waste or to an approved designated facility (e.g., recycling facility).
Documentation and Reporting:
Manifests: Hazardous waste that is sent to a TSDF or an approved designated facility must be listed
on a Uniform Hazardous Waste Manifest A manifest provides a description of the hazards of the
waste and the waste handlers. You must sign and date the manifest and obtain the signature of the
transporter on the manifest. You must also keep this copy of the form until you receive a copy
signed by the TSDF. Manifests must be kept for at least 3 years from the date of shipment. If your
generator status changes, you must notify EPA.
Land Disposal Restriction: Many types of hazardous waste are restricted from being disposed in
or on the land due to the probability of groundwater or soil contamination. The manifest for these
wastes must be accompanied by a Land Disposal Restriction (LDR) notification. The LDR is a
one-time notification form that is signed by you, the generator, and indicates that you understand
this waste cannot be land disposed. According to federal regulations., it is the responsibility of the
generator to provide the manifest and the LDR. Most hazardous waste disposal contractors will
supply one or both of these forms for you.
Exception Report: Once a hazardous waste manifest has been signed and dated by you (the
generator), EPA gives the disposal contractor 60 days to transport the waste to the TSDF and
return a signed copy of the manifest to you. If, after 60 days, you do not receive the "Return to
Generator" copy of the manifest signed by the TSDF, you must send a legible photocopy of the
manifest to the EPA Regional Administrator and a brief written statement about not receiving the
signed copy. This report must be maintained for at least 3 years.
Miscellaneous: Generators are also required to keep records of test results, waste analyses, or
other waste determinations for at least 3 years from the date of shipment of that waste.
Storage/containers: You can store hazardous waste in tanks or containers, provided they are not leaking,
bulging, rusted, or incompatible with the waste stored in them (e.g., certain types of acid in metal
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containers) (40 CFR Part 262.34). Storage areas should have a means of secondary containment, an
alarm, a fire extinguisher, a "No Smoking" sign, and a means of communication (e.g., walkie-talkie, cellular
phone, or air horn) in the event of a spill or other emergency.
Labeling: Hazardous waste tanks and containers must be labeled with the words "Hazardous Waste", the
contents of the container, the accumulation start date, the waste codes of the contents, and the EPA ID
number of the generator. A standard yellow hazardous waste label can usually be obtained through your
EPA or State office, or through some catalogs.
Storage/time limitations: SQGs are required to dispose their hazardous waste within 180 days of placing
the waste into the container. The exception to this is if the facility elects to "satellite" its waste first If you
satellite your waste, you must collect it in a container "at or near the point of generation." The
interpretation of "at or near" varies from state to state but generally means the container cannot be
separated by a door or wall from the point of generation and cannot be more than 50 feet from the point
of generation. The container must be labeled only with its contents. Most states allow satellite generation
of up to 55 gallons of one type of waste. Once the 55-gallon limit has been reached, the waste must be
moved to an onsite accumulation area or building where it can be stored for up to 180 days from that time.
Note about Episodic Generators'. Depending on your type of business, you might be regulated under
different rules at different times. If, in June, you generate between 220 and 2,200 Ibs (100 kg to 1,000 kg)
of hazardous waste, you would be considered an SQG for June and your waste would then be subject to the
management requirements for SQGs. If, for example, you generate less than 220 Ibs (100 kg) of
hazardous waste during the month of June, your generator status would change and you would be
considered a CESQG for June. Your June waste would be subject to the hazardous waste management
requirements for CESQGs.
ADDITIONAL INFORMATION
Contacts:
• General information regarding the EPA - http://www.epa.gov
RCRA Hotline at 1-800-424-9346.
Publications:
Hazardous Waste: The Conditionally Exempt Small Quantity Generator Fact Sheet
Hazardous Waste: The Large Quantity Generator Fact Sheet
Hazardous Waste: Determining Your Generator Status Fact Sheet
Identifying Hazardous Waste Fact Sheet
How Do I Dispose of Waste Containers! Fact Sheet
Hazardous Waste Contingency Planning and Notification Fact Sheet
Do I Need a Hazardous Waste Generator Identification Number? Fact Sheet
Understanding the Hazardous Waste Rules: A Handbook for Small Businesses — 1996 Update
EPA 530-K-95-001, June 1996
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