United States
        Environmental Protection Agency
        Washington DC 20460

        EPA/530-SW-86-003      March 1986
x>EPA  Hazardous

        Small Quantity
        Generators of
        100 to 1000

TTn 1976, Congress enacted the Resource
JlConservation 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 large generators who
produce the greatest portion of hazardous waste.
Regulations EPA published on May 19, 1980,
exempted "small quantity
generators"—establishments producing less than
1000 kilograms of hazardous waste in a calendar
month—from most of the hazardous waste
  On November 8, 1984, however, the
Hazardous and Solid Waste Amendments
(HSWA) were signed into  law. These
amendments to RCRA directed EPA to establish
new requirements for smaJJ quantity generators
who produce between 100 and 1000 kilograms
of hazardous waste in a calendar month. EPA
issued final regulations for these 100 to 1000
kg/mo generators on March 24, 1986, making the
elective date of the requirements September 22,
  In general, the new regulations for 100 to 1000
kg/mo generators are based upon the existing
hazardous waste regulatory program. To lessen
the burden on the small businesses which are
most likely to be affected by these new
regulations, EPA has exempted 100 to 1000
kg/mo generators from some of the
administrative and paperwork requirements
applicable to larger generators (1000 or more
kg/mo). Here are answers to some basic
questions about the new requirements:
Who is affected by these new regulations?

Establishments that generate from 100 to 1000
kilograms (approximately 220 to 2200 pounds)
of hazardous waste in any calendar month.
(Depending upon the weight of the contents,
this amount is approximately one half-full to
five full 55-gallon drums.)

What kinds of businesses are likely to be 100 to
1000 kg/mo generators?

Vehicle maintenance establishments (such as
garages, paint and body shops, and car
dealerships), metal manufacturers, printers,
laundries and dry cleaners, chemical
manufacturers and formulators, laboratories,
equipment repair shops, construction firms,
textile manufacturers, pesticide applicators, and

     schools are among establishments likely to
     produce small quantities of hazardous waste.
     Based on a March 1985 survey of small quantity
     generators, EPA estimates that there are
     approximately 100,000 businesses which would
     be affected by the new regulations.

     What new requirements must 100 to 1000
     kg/mo generators meet?

     By September 22, 1986, 100 to 1000 kg/mo
     generators must:
     o Obtain a U.S. EPA Identification Number.

     o Use the full Uniform Hazardous Waste
     Manifest system when shipping hazardous
     waste off-site.

     o Offer wastes only to hazardous waste
     transporters who have U.S. EPA  Identification

     o Accumulate waste on-site for no more than
     180 days, or 270 days if the waste is to be
     shipped more than 200 miles, unless they obtain
     a hazardous waste permit.
     o Ensure that their hazardous waste is managed
     at a hazardous waste facility with interim status
     or a permit under RCRA.

L£  Are these the  only new requirements that 100 to
     1000 kg/mo generators must meet?

     Not necessarily. While the items listed above
     briefly identify the basic new federal
     requirements for 100 to 1000 kg/mo generators,
     the actual requirements which go into effect on
     September 22, 1986 are more detailed. In
     addition,  some states may impose more stringent
     requirements on small quantity generators. For
     example,  four states (California, Louisiana,
     Minnesota, and  Rhode Island] now fully regulate
     all generators  of hazardous waste, 100 to 1000
     kg/mo generators as well as larger and smaller
     generators. To be sure you understand all the
     requirements, state and federal, that you must
     meet, contact  your state hazardous waste
     management agency.

     What is a U.S. EPA Identification Number, and
     how do I obtain one?

     A U.S. EPA Identification Number is a unique,
     12-character number that EPA assigns to
     generators and transporters of hazardous  waste,
     and to owners/operators of facilities that treat,

store, or dispose of hazardous waste. The
identification numbers help EPA and states
compile and maintain a database on hazardous
waste activities.
  To obtain an EPA Identification Number, you
should complete EPA Form 8700-12,
"Notification of Hazardous Waste Activity," or a
similar form used by your particular state. To
request  the application form, contact your state
hazardous waste management agency or EPA
Regional Office. Along with the appropriate
application form , you will receive instructions
for completing the form and information on
where you can get additional assistance.

Where do I  obtain the Uniform Hazardous
Waste Manifest to use when I ship my
hazardous waste off my plant site?

A hazardous waste manifest is a multi-copy
form that you must fill out completely and use
to accompany your hazardous waste shipments.
Some states print their own versions of the
Manifest with the state's name and logo and
require use of the state Manifest form. These
forms are available from state hazardous  waste
management agencies. Many transporters and
facilities may also be able to provide you with
the correct Manifest.
  To determine which state's Manifest form you
need to  complete, use this system: (1) If the state
to which you are shipping your waste has its
own Manifest, use that Manifest form (2). If not,
use the Manifest of the state in which your
waste was generated. (3) If neither state requires
a state-specific Manifest, you may use the
"general" Uniform Hazardous Waste
Manifest — EPA Form 8700-22 — which you can
purchase from some commercial printers, or
obtain from  some transporters or waste
management facilities.

What information is required on the Manifest?

Effective September 22,  1986, federal law
requires 100 to  1000 kg/mo generators to fill out
all of the unshaded items on the Uniform
Hazardous Waste Manifest. (The completed
Manifest will also fully satisfy Department of
Transportation requirements for shipping
hazardous materials.) Even now, some states
require generators to complete the entire
Manifest, or to provide information beyond the
items 3, 9, 11, 12, 13,  14, and  16 required under
federal law as of August 5, 1985. To be sure you
complete all necessary parts of the Manifest,
contact your state hazardous waste agency,  your
transporter, and your receiving facility.

     Why are there multiple copies of the Manifest?

     The Manifest form is designed so that shipments
     of hazardous waste can be tracked from their
     point of generation to their final destination, the
     so-called "cradle-to-grave" system. The Manifest
     is produced in a multi-copy format so that each
     step in the shipment process can be
     documented. Thus, the generator of the
     hazardous waste completes the Manifest, and
     turns the shipment and remaining copies of the
     Manifest over to the transporter. The transporter
     or hauler signs the Manifest, returns one copy to
     the generator, and turns the shipment and
     Manifest over to the facility that the generator
     designated to receive the waste. The facility
     signs the Manifest, gives one copy back to the
     transporter, keeps a copy, and sends the
     remaining copy back to the generator so the
     generator knows that the hazardous waste has
     reached its intended destination. Some states
     require that a copy of the Manifest also be sent
     to the state hazardous waste agency each time a
     shipment changes hands.  Generators are
     required to keep a copy of each Manifest, signed
     by the designated facility, in their files for three
     years following the date of the shipment.

     What if the generator does not receive a final
     copy of the Manifest confirming the facility's
     receipt of the shipment?

.A.  Under the new federal regulations, 100 to 1000
     kg/mo generators are not, as  are larger
     generators, required to file "exception reports."
     However, while these generators are not
     required to file an exception report, EPA
     strongly encourages generators to use good
     business practice  and perform the necessary
     follow-up to make sure their waste shipments
     reach the destination facility. Should a shipment
     be truly lost, it is  in the generator's interest to
     notify EPA or the state in  order to minimize any
     future liability.

How often should generators ship hazardous
waste off their premises?

Larger generators must ship their waste off-site
at least every 90 days to avoid  having to obtain
a hazardous waste facility permit. The final
regulations allow 100 to 1000 kg/mo generators
to accumulate hazardous waste on-site for 180
days (or up to 270 days if the waste is to be
shipped more than 200 miles) without the need
for a permit so that generators may accumulate
more economical quantities for shipment. Some
states, however,  allow only a 90-day
accumulation period, even for  100 to 1000
kg/mo generators. Check with your state
hazardous waste agency for information on the
requirements that apply to you.

Where can I send my waste, and who can
haul it?

Since hazardous waste from 100 to 1000 kg/mo
generators must be managed according to RCRA
hazardous waste rules, only transporters and
facilities  which have EPA identification
numbers  can handle  your hazardous waste.
Furthermore, they must be authorized to handle
your particular kind  of hazardous waste. For
information on hazardous waste transporters
and management facilities in your area, contact
your state hazardous waste agency or EPA
regional office.

May I recycle my hazardous waste?

Yes. In fact, EPA strongly encourages recycling
as one of the best methods for managing
hazardous waste. Waste shipped off-site for
recycling may still be subject to manifesting as
well as other transportation and storage
requirements. These  requirements, however, are
not intended to discourage recycling. Contact
your state hazardous waste agency, EPA regional
office, or trade association for information on
your specific waste recycling alternatives.

Where can small quantity generators get further
information and assistance?

Generators should contact their state hazardous
waste agencies for information on the
requirements they must meet. For questions on
the new federal requirements or hazardous
waste regulations in general, or to obtain the
number for their state hazardous waste agencies,
generators may wish to contact their EPA

         regional office (see list below); EPA's toll-free
         RCRA Hotline, 800-424-9346 (in Washington,
         DC, 382-3000); or EPA's toll-free Small Business
         Hotline, 800-368-5888 (in Virginia,
EPA Regional Offices

EPA Region 1
JFK Federal Building
Boston, MA 02203
Connecticut, Massachusetts,
Maine, New Hampshire, Rhode
Island, Vermont
EPA Region 2
26 Federal Plaza
New York, NY 10278
New Jersey, New York, Puerto
Rico, Virgin Islands
EPA Region 3
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-9800
Delaware, Maryland,
Pennsylvania, Virginia, West
Virginia, District of Columbia
EPA Region 4
345 Courtland Street, N.E.
Atlanta, GA 30365
Alabama, Florida, Georgia,
Kentucky, Mississippi, North
Carolina, South Carolina,
EPA Region 5
230 South Dearborn Street
Chicago, IL 60604
Illinois, Indiana, Michigan,
Minnesota, Ohio, Wisconsin
EPA Region 6
1201 Elm Street
Dallas, TX 75270
Arkansas, Louisiana, New
Mexico, Oklahoma, Texas
EPA Region 7
726 Minnesota Avenue
Kansas City, KS 66101
Iowa, Kansas, Missouri,
EPA Region 8
One Denver Place
999 18th Street
Suite 1300
Denver, CO 80202-2413
Colorado, Montana, North
Dakota, South Dakota, Utah,
EPA Region 9
215 Fremont Street
San Francisco, CA 94105
Arizona, California, Hawaii
Nevada, American Samoa,
Guam, Trust Territories of the
EPA Region 10
1200 Sixth Avenue
Seattle, WA 98101
Alaska, Idaho, Oregon,