MANAGING YOUR
HAZARDOUS WASTE:
A Guide for Small Businesses
II 1' jti\ United States
Environmental Protection
*•1IF L^l m m Agency
October 2019
EPA 530-K-19-001
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TABLE OF CONTENTS
INTRODUCTION 1
DECIDING WHETHER HAZARDOUS WASTE REGULATIONS APPLY TO YOU 2
Defining Hazardous Waste 2
Finding Your Generator Category. 3
WHAT HAZARDOUS WASTE DO YOU COUNT TO DETERMINE YOUR GENERATOR CATEGORY? 5
DO Count 5
DO NOT Count 5
UNIVERSAL WASTES AND USED OIL 6
Universal Wastes 6
Used Oil 6
Storage 7
Oil Leaks or Spills 7
SUMMARY OF REQUIREMENTS FOR VERY SMALL QUANTITY GENERATORS 8
SUMMARY OF REQUIREMENTS FOR SMALL QUANTITY GENERATORS 10
Obtaining an EPA Identification Number 10
Managing Hazardous Waste On Site 13
Accumulating Your Waste 13
Treating Your Waste to Meet the Land Disposal Restrictions 13
Preventing Accidents 13
Responding to Emergencies 15
Shipping Waste Off Site 17
Choosing a Treatment, Storage, and Disposal Facility. 17
Preparing Waste Shipments 17
Preparing Hazardous Waste Manifests 18
Land Disposal Restriction Reporting Requirements 18
Export Notification 18
Closure 18
SUMMARY OF REQUIREMENTS FOR LARGE QUANTITY GENERATORS 20
WHERETO GET MORE HELP 21
EPA and Other Federal Resource Centers 22
EPA Regional Offices 23
ABBREVIATIONS AND DEFINITIONS 25
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INTRODUCTION
Does your business generate hazardous waste? Many small
businesses do. If you need help understanding which federal
hazardous waste management regulations apply to your
business, this handbook is for you. It has been prepared
by the U.S. Environmental Protection Agency (EPA) to help
small-business owners and operators understand how
best to comply with federal hazardous waste management
regulations.
This handbook provides an overview of the regulations to
give you a basic understanding of your responsibilities when
generating and managing hazardous waste. It should not be
used as a substitute for the actual reguirements. All of the
federal hazardous waste regulations are located in Title 40 of
the Code of Federal Regulations (CFR), Parts 260 to 299
(www.ecfr.gov).
EPA defines three categories of hazardous waste generators
based upon the guantity of hazardous waste they generate
per month:
1. Very small quantity generators (VSQGs), which
generate less than 100 kilograms (kg) or 220 pounds
(lbs) per month.
2. Small quantity generators (SQGs), which generate
between 100 and 1,000 kg (220 and 2,200 lbs) per
month.
3. Large quantity generators (LQGs), which generate
more than 1,000 kg (2,200 lbs) per month.
Words or phrases that appear in bold red text
throughout this guide are defined in the "Abbreviations
and Definitions"section, starting on page 25.
Each category of generator must comply with the hazardous
waste rules specific to that category.This handbook is
intended primarily to help SQGs and VSQGs (that is, busi-
nesses that generate a small guantity of hazardous waste)
learn about regulations that apply to them.
This handbook explains only the federal reguirements for
hazardous waste management. Many implementing
agencies (e.g., states) have their own hazardous waste
regulations based on the federal hazardous waste regulations.
Some use the federal reguirements and definitions; others
have developed more stringent reguirements. If the latter
is true foryour implementing agency, you must comply
with those more stringent regulations.To become familiar
with your local reguirements, consult your implementing
hazardous waste agency. For the address or phone
numberforyour implementing aaencv.visit www.epa.aov/
hwaenerators/links-hazardous-waste-proarams-and-us-state-
environmental-aaencies.
Some generators hire a waste management company to
address all hazardous waste management obligations.
Remember, even if working with an outside firm, you are
ultimately responsible for the proper management of your
hazardous waste throughout its life cycle from cradle to
grave.
HAZARDOUS WASTE GENERATOR IMPROVEMENTS RULE
On November 28,2016, EPA finalized a wide-ranging revision of the hazardous waste generator regulations, called the
Hazardous Waste Generator Improvements Rule.This final rule added flexible standards for episodic generation and
consolidation of waste from VSQGs at LQGs, discussed on pages 3 and 9 of this handbook. The final rule also made other
changes throughout the hazardous waste generator regulations, revising standards for hazardous waste determinations,
marking and labeling of hazardous waste units, emergency planning and preparedness, and closure, among others. Some
of these revised standards are mandatory for states to adopt, as they are more stringent than previous regulations. For more
information, see the webpage for the final rule (www.epa.aov/hwaenerators/final-rule-hazardous-waste-aenerator-im-
provements) or read the rule itself in the Federal Register at 81 FR 85732.
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DECIDING WHETHER HAZARDOUS
WASTE REGULATIONS APPLY TO YOU
Federal hazardous waste management regulations apply
to most businesses that generate hazardous waste. To
determine if these regulations apply to your business, you
must first determine if you even generate hazardous waste.
FIRST STEPS
• Determine if you generate hazardous waste in the
first place.
• Count the amount of hazardous waste that you
produce per month.
• Determine your generator category to learn the
management reguirements that apply to you.
Defining Hazardous Waste
A waste is any solid, liguid, or contained gaseous material
that is discarded by being disposed of, burned or inciner-
ated, or recycled. (There are some exceptions for recycled
materials.) It can be the byproduct of a manufacturing
process or simply a commercial product that you use
in your business—such as a cleaning fluid or battery
acid—and that is being disposed of. Even materials that are
recyclable or can be reused in some way (such as burning
solvents for fuel) may be considered waste.
Hazardous waste can be one of two types:
• Listed waste. Your waste is considered hazardous if
it appears on one of four lists published in the CFR
(40 CFR Part 261 Subpart D). Currently, more than
500 wastes are listed using a four-character code of
one letter and three numbers. Wastes are listed as
hazardous because they are known to be harmful
to human health and the environment when not
managed properly. Some common listed hazardous
wastes are spent solvents (F001-F005) and sludge from
the treatment of electroplating wastewaters (F006).
Even when managed properly, some listed wastes are
so dangerous that they can be fatal to humans even in
low doses; these are called acute hazardous wastes.
Examples of acute hazardous wastes include beryllium
powder and certain discarded pesticides.
• Characteristic wastes. If your waste does not appear
on one of the hazardous waste lists, it still might be
considered hazardous if it exhibits one or more of the
following characteristics:
» It catches fire under certain conditions.This is
known as an ignitable waste. Examples are paints
and certain degreasers and solvents.
» It corrodes metals or has a very high or low pH.
This is known as a corrosive waste. Examples are
rust removers, acid or alkaline cleaning fluids, and
battery acid.
» It is unstable and explodes or produces toxic
fumes, gases, and vapors when mixed with water
or under other conditions such as heat or pressure.
This is known as a reactive waste. Examples are
certain cyanides or sulfide-bearing wastes.
» It is harmful or fatal when ingested or absorbed, or
it leaches toxic chemicals into the soil or ground
water when disposed of on land. This is known as a
toxic waste. Examples are wastes that contain high
concentrations of heavy metals, such as cadmium,
lead, or mercury.
You can determine if your waste is toxic by having it tested
using the Toxicity Characteristic Leaching Procedure
(TCLP), or by simply knowing that your waste is hazardous
or that your processes generate hazardous waste. For more
information about theTCLP and othertest methods, see
www.epa.gov/hw-sw846.
IDENTIFYING YOUR WASTE
To help you identify some of the waste streams
common to your business, the table on page 4
provides a list of typical hazardous wastes generated
by small businesses.
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Commercial chemical products that are discarded might
also become hazardous waste. For a complete listing of these
hazardous wastes, see 40 CFR 261.33 (P- and U-waste codes).
If your waste is hazardous, you will need to manage it accord-
ing to appropriate federal or state regulations. When in doubt
about whether a waste is hazardous, it is always allowable to
manage it as hazardous waste.
Finding Your Generator Category
Once you know that you generate hazardous waste, you
need to count the amount of it you produce per month.This
amount determines your generator category.
Many hazardous wastes are liguids and are measured in
gallons—meaning that you will need to convert gallons
to kilograms or pounds to count those wastes.To do this,
you must know the liguids'density. A rough guide is that
30 gallons (about half of a 55-gallon drum) of waste with a
density similar to water weighs about 100 kg (220 lbs); 300
gallons of a waste with a density similar to water weighs
about 1,000 kg (2,200 lbs).
EPA has established three generator categories, each of which
is regulated differently:
• VSQGs (Very Small Quantity Generators). You are
considered a VSQG if you generate less than 100 kg (220
lbs) per month of hazardous waste. You are exempt from
hazardous waste management regulations, provided
that you comply with the basic reguirements described
TIP
One way to help determine if your waste has any
of the characteristics listed on page 2 is to check
Safety Data Sheets (SDSs), which come with all
products containing hazardous materials (see www.
msdsonline.com for information). In addition, your
national trade association or its local chapter might
be able to help you.
on page 8. If you are a VSQG and you generate no more
than 1 kg (2.2 lbs) of acute hazardous waste—or 100 kg
(220 lbs) of acute hazardous waste spill residues—in a
calendar month, you may manage the acute hazardous
waste according to the VSQG reguirements.
• SQGs (Small Quantity Generators). You are considered
an SQG if you generate between 100 and 1,000 kg (220
and 2,200 lbs) per month of hazardous waste. SQGs must
comply with EPA reguirements for managing hazardous
waste described in this document.
• LQGs (Large Quantity Generators). You are considered
an LQG if you generate more than 1,000 kg (2,200 lbs) per
month of hazardous waste or 1 kg (2.2 lbs) per month of
acute hazardous waste. LQGs must comply with more
extensive hazardous waste rules than those summarized
in this handbook. See page 20 for an overview.
EPISODIC EVENTS
Sometimes an incident bumps a generator that is normally an SQG or VSQG into a larger generator category for a short
period. EPA calls this an "episodic event"and it can happen because of a planned cleanout, a small project, an unplanned
recall, or even a spill.
If this happens to you, you might be eligible for a streamlined set of reguirements designed to keep smaller generators
from having to comply with more extensive generator regulations because of an uncommon event. However, all the
hazardous waste you generate will have to be sent with a manifest to a hazardous waste treatment and disposal facility
or a recycler.
Some reguirements that will apply to the SQG or VSQG are notifying the state (or EPA) using the Site ID form (see pages
11-12) if you will be holding an event, labeling the waste, managing the waste to prevent spills and releases, and
completing the entire event and getting the waste off site within 60 days.The complete regulations for episodic events
are found in 40 CFR Part 262 Subpart L.
Note: Not every case of increased waste production will gualify as an episodic event. Make sure your situation is eligible.
In addition, you should first check with your state to see if it has adopted this part of the regulations, as state reguire-
ments can be more stringent than the federal reguirements.
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TYPICAL HAZARDOUS WASTE GENERATED BY SMALL BUSINESSES
Type of Business
How Generated
Typical Wastes
Waste Codes
Dry cleaning
Commercial dry cleaning processes
Distillation residues, spent filter
cartridges, cooked powder
residues, spent solvents, unused
perchloroethylene
D001, D039, F002, F005,U210
Furniture
manufacturing and
refinishing
Construction and surface preparation,
staining and painting, finishing, brush
and spray brush cleaning
Ignitable wastes, toxic wastes,
solvent wastes, paint wastes
D001-D003, D007, D008, D035,
D040 F001-F003, F005, U002, U080,
U159, U161,U220, U223, U239
Construction,
demolition, and
renovation
Land-clearing, wrecking, and demo-
lition; heavy construction; carpentry
and floorwork; paint preparation
and painting; specialty contracting
activities
Ignitable wastes, toxic wastes,
solvent wastes, paint wastes, used
oil, acids/bases
D001, D002, D004, D006-D009,
D01 8, D021, D023-D026, D034,
D035, D037, D040, F001-F003, F005,
U002, U037, U080, U131, U159,
U161,U220, U239
Laboratories
Diagnostic and other laboratory
testing
Spent solvents, unused reagents,
reaction products, testing samples,
contaminated materials
D001, D002, D003, F001-F005, U211
Vehicle
maintenance
Air conditioner maintenance; body
repair and refinishing; car washing;
battery and oil/fluids replacement;
rustproofing, painting, and paint
removal; parts washing and degreas-
ing; radiator repair; product storage
and storage tank cleaning; shop
cleanup
Acids/bases, solvents, ignitable
wastes, toxic wastes, paint wastes,
spent rags and wipes, batteries,
used oil, oil filters, unused cleaning
chemicals, airbag inflators
D001, D002, D003, D006-D008,
D01 8, D035, D040, F001-F002, F005,
U002, U075, U080, U134, U154,
U159, U161,U220, U228, U239
Printing
Using ink in lithography, letterpress,
screen printing, flexography, and
gravure; plate processing; cleaning
printing equipment; developing
negatives and prints; printing
processes
Acids/bases, heavy metal wastes,
spent organic solvents, toxic
wastes, waste and unused ink,
unused chemicals
D001, D002, D005-D007, D008,
D011, D01 8, D019, D021, D035,
D039, D040, D043, F001-F005, U002,
U01 9, U043, U055, U056, U069,
U080, U112, U122, U154, U159,
U161,U210, U211,U220, U223,
U226, U228, U239, U259, U359
Equipment repair
Degreasing, equipment cleaning, rust
removal, paint preparation, painting,
paint removal, spray booth, spray
guns, and brush cleaning
Acids/bases, toxic wastes, ignitable
wastes, paint wastes, solvents
D001, D002, D006, D008, F001-F005
Pesticide end users/
application services
Pesticide application and cleanup
Used/unused pesticides,
solvent wastes, ignitable wastes,
contaminated soil (from spills),
contaminated rinse water, empty
containers
D001, F001-F005, U129, U1 36, P094,
PI 23
Educational and
vocational shops
Automobile engine and body repair,
metalworking, graphic arts-plate
preparation, woodworking
Ignitable wastes, solvent wastes,
acids/bases, paint wastes
D001, D002, F001-F005
Photo processing
Processing and developing neg-
atives/prints; washing, stabilizing,
system cleaning
Acid regenerants, dichro-
mate-based and system cleaners,
photographic activators, corrosive
and ignitable wastes, silver
D001, D002, D007, D011
Leather
manufacturing
Soaking; hair removal, deliming,
bating; tanning; retanning, dyeing,
fatliquoring; buffing coating
Acids/bases, ignitable wastes, toxic
wastes, solvent wastes, unused
chemicals, wastewater, suspended
solids, alcohols
D001, D002, D003, D007, D035,
F001-F005
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WHAT HAZARDOUS WASTE DO YOU
COUNT TO DETERMINE YOUR GENERATOR
CATEGORY?
DO Count...
All quantities of listed and characteristic hazardous wastes
that are:
• Accumulated on the property for any period of time
before disposal or recycling. (Dry cleaners, for example,
must count any residue removed from machines, as
well as spent cartridge filters.)
• Packaged and transported away from your business.
• Placed directly in a regulated treatment or disposal unit
at your place of business.
• Generated as still bottoms or sludges and removed
from product storage tanks.
DO NOT Count...
Wastes that:
• Are specifically exempted from counting. Examples
include lead-acid batteries that will be reclaimed,
scrap metal that will be recycled, used oil managed
underthe used oil provisions of 40 CFR Part 279, and
universal wastes (e.g., batteries, pesticides, thermostats,
lamps) managed under40 CFR Part 273.
• Might be left in the bottoms of containers that have
been thoroughly emptied through conventional
means, such as pouring or pumping. Note that this
applies to non-acute hazardous waste.
• Are left as residue in the bottoms of tanks storing
products, until the residue is removed from the
product tank.
• Are reclaimed continuously on site without storing
before reclamation, such as dry cleaning solvents.
• Are managed in an elementary neutralization unit,
a totally enclosed treatment unit, or a wastewater
treatment unit without being stored first. (See
"Abbreviations and Definitions"on page 25 for an
explanation of these types of units.)
Are discharged directly to publicly owned treatment
works (POTWs) without being stored or accumulated
first. Such discharges to a POTW must comply with
the Clean Water Act. POTWs are public utilities, usually
owned by the city, county, or state, that treat industrial
and domestic sewage for disposal.
Have already been counted once during the calendar
month, and are treated on site or reclaimed in some
manner, then used again.
Meet special, limited requirements for managing
certain commonly generated wastes.These wastes can
be managed following the less burdensome require-
ments referenced below instead of the usual hazardous
waste requirements. Check with your state agency to
determine if your state has similar regulations.
» Scrap metal that is recycled—40 CFR 261.6(a)(3).
» Unused commercial chemical products and
other unwanted materials generated under the
special requirements for a cleanout of an academic
laboratory—40 CFR Part 262 Subpart K.
» Hazardous waste managed as part of an
infrequent episodic event—40 CFR Part 262
Subpart L.
» Lead-acid batteries that are reclaimed—40 CFR
Part 266 Subpart G.
» Pharmaceuticals being managed by healthcare
facilities and reverse distributors—40 CFR Part 266
Subpart P.
» Universal wastes (e.g., certain batteries, recalled
and collected pesticides, mercury-containing
equipment, lamps)—40 CFR Part 273 (see page 6).
» Used oil—40 CFR Part 279 (see pages 6-7).
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UNIVERSAL WASTES AND USED OIL
Universal Wastes
Universal wastes are potentially hazardous items commonly
thrown into the trash by households and small businesses.
The universal waste program was developed to streamline
environmental regulations for these wastes generated by
large numbers of businesses in relatively small quantities.
It is designed to reduce the amount of hazardous waste dis-
posed of as municipal solid waste, encourage the recycling
and proper disposal of certain common hazardous wastes,
and reduce the regulatory burden for businesses that
generate these wastes.
Although handlers of universal wastes can meet less
stringent standards for storing, transporting, and collecting
these wastes, handlers must still comply with the full
hazardous waste requirements for final recycling, treatment,
or disposal. By providing a waste management structure
that removes these wastes from municipal landfills and
incinerators, this program ensures stronger safeguards for
public health and the environment.
Universal wastes include:
• Batteries, such as nickel-cadmium (Ni-Cd), small sealed
lead-acid batteries, and lithium-ion batteries, which are
found in many common items, including electronic
equipment, cell phones, portable computers, power
tools, and emergency backup lighting.
• Agricultural pesticides that have been recalled
or banned from use, are obsolete, have become
damaged, or are no longer needed due to changes
in cropping patterns or other factors.They often are
stored for long periods in sheds or barns.
• Mercury-containing equipment, including thermo-
stats, thermometers, and other devices, which can
contain as much as 3 grams of liquid mercury and are
found in almost any commercial, industrial, agricultural,
community, and household building.
• Lamps, which can contain mercury and sometimes
lead, such as fluorescent, high-intensity discharge (HID),
neon, mercury vapor, high-pressure sodium, and metal
halide lamps found in businesses and households.
Other types of wastes can be added to the universal waste
list by EPA or authorized states. For updates, check www,
epa.aov/hw/universal-waste for the latest information.
The universal waste program also encourages communities
and businesses to establish collection programs or
participate in manufacturer take-back programs required
by a number of states. Many large manufacturers and
trade associations manage national and regional collection
programs for their universal waste products. For more
information, see 40 CFR Part 273.
Used Oil
EPA's used oil management standards are a set of "good
housekeeping"requirements that encourage used oil
handlers to recycle used oil instead of disposing of it. Used
oil can be collected, refined and recycled, and used again—
for the same job or a completely different use.
Used oil is defined as "any oil that has been refined from
crude oil or any synthetic oii that has been used and, as a
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result of such use, is contaminated by physical or chemical
impurities." To meet EPA's definition of used oil, a substance
must meet each of the following criteria:
• Origin. Used oil must have been refined from crude oil or
made from synthetic materials. Used animal and vegeta-
ble oils are excluded from EPA's definition of used oil.
• Use. Oils used as lubricants, hydraulic fluids, heat
transfer fluids, buoyants, and for other similar purposes
are considered used oil. Oils such as bottom cleanout
waste from virgin fuel oil storage tanks or virgin fuel oil
recovered from a spill do not meet EPA's definition of
used oil because these oils have never been used. EPA's
definition also excludes products used as cleaning agents
or solely for their solvent properties, as well as certain
petroleum-derived products such as antifreeze and
kerosene.
• Contaminants.To meet EPA's definition, used oil must
become contaminated as a result of being used.This
includes residues and contaminants generated from
handling, storing, and processing used oil. Physical
contaminants can include dirt, metal scrapings, or
sawdust. Chemical contaminants could include solvents,
halogens, or saltwater.
The following are types of used oil handlers:
• Generators are businesses that handle used oil through
commercial or industrial operations orfrom the main-
tenance ofvehicles and eguipment. Examples include
car repair shops, service stations, government motor
pools, grocery stores, metalworking industries, and boat
marinas. Farmers who produce less than an average
of 25 gallons of used oil per month are excluded from
generator status. Individuals who generate used oil
through the maintenance of their personal vehicles and
eguipment are not subject to regulation underthe used
oil management standards.
• Collection centers and aggregation points are facilities
that accept small amounts of used oil and store it until
enough is collected to ship it elsewhere for recycling.
• Transporters are companies that pick up used oil from
all sources and deliver it to re-refiners, processors, or
burners.
• Transfer facilities are any structures or areas where used
oil is held for longer than 24 hours, but not longer than
35 days.
• Re-refiners and processors are facilities that blend or
remove impurities from used oil so the oil can be burned
for energy recovery or reused.
• Burners burn used oil for energy recovery in boilers,
industrial furnaces, or in hazardous waste incinerators.
• Marketers are handlers that either (a) direct shipments of
used oil to be burned as fuel in regulated devices or (b)
claim that certain EPA specifications are met for used oil
to be burned for energy recovery in devices that are not
regulated.
Although different used oil handlers have specific reguire-
ments, the following reguirements are common to all types
of handlers:
Storage
• Label all containers and tanks as "used oil."
• Keep containers and tanks in good condition. Do not
allow tanks to rust, leak, or deteriorate. Fix structural
defects immediately.
• Never store used oil in anything otherthan tanks and
storage containers. Used oil also can be stored in units
that are permitted to store regulated hazardous waste.
Oil Leaks or Spills
• Take steps to prevent leaks and spills. Keep machinery,
eguipment, containers, and tanks in good working
condition, and be careful when transferring used oil.
Keep sorbent materials available at the site.
• If a leak or spill occurs, stop the oil from flowing at the
source. If a leak can't be stopped, put the oil in another
holding container ortank.
• Contain spilled oil using sorbent berms or by spreading
sorbent over the oil and surrounding area.
• Clean up the used oil and recycle it as you would have
before it was spilled. If recycling is not possible, you must
first make sure the used oil is not a hazardous waste and
dispose of it appropriately. You also must handle all used
cleanup materials that contain used oil, including rags
and sorbent booms, according to the used oil manage-
ment standards.
• Remove, repair, or replace the defective tank or container
immediately.
Used oil reguirements are detailed in 40 CFR Part 279. For
more information, see the regulations or www.epa.gov/hw/
manaaina-used-oil-answers-freguent-guestions-businesses.
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SUMMARY OF REQUIREMENTS FOR
VERY SMALL QUANTITY GENERATORS
If you generate no more than 100 kg (220 lbs) of
hazardous waste per month, you are a VSQG. You must
comply with three basic waste management requirements
to remain exempt from the full hazardous waste
regulations that apply to generators of larger quantities
(SQGs and LQGs). (Note: there are different quantity limits
for acute hazardous waste.)
First, you must identify all hazardous waste that you
generate. Second, you may not store more than 1,000 kg
(2,200 lbs) of hazardous waste on site at any time. Finally,
you must ensure delivery of your hazardous waste to an
off-site treatment or disposal facility that is one of the
following (or if you treat or dispose of your hazardous
waste on site/your facility also must be):
• A state or federally regulated hazardous waste
management treatment, storage, or disposal
facility (TSDF).
• A facility permitted, licensed, or registered by a state
to manage municipal or industrial solid waste.
• A facility that uses, reuses, or legitimately recycles
the waste (or treats the waste prior to use, reuse, or
recycling),
• A universal waste handler or destination facility
subject to the universal waste requirements of 40
CFR Part 273 (Universal wastes are wastes such as
batteries, recalled and collected pesticides, mercu-
ry-containing thermostats and other equipment, or
lamps.)
• An LQG under the control of the same person as the
VSQG, provided the VSQG marks its containers with
the words "Hazardous Waste"and the hazards ofthe
contents ofthe container (e.g., ignitable, corrosive,
toxic, or reactive or another nationally recognized
hazard label).
STATE REQUIREMENTS
Some states have additional requirements for
VSQGs. For example, some states require VSQGs:
to follow some ofthe SQG requirements, such as
obtaining EPA identification numbers or comply-
ing with storage standards. See page 13 for SQG
storage requirements.
Suggestion:
It's a good idea to call the appropriate implementing
agency to verify the TSDF you have selected has the
necessary permits, etc. You also may want to see that the
facility fits into one ofthe above categories. (It's a good
idea to document such calls foryour records.)
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WASTE CONSOLIDATION FROM VSQGS
If you are a VSQG that is part of a larger company, you may be able to reduce your overall environmental liability,
improve the management of your hazardous waste, and reduce overall waste management costs by consolidating
yourVSQG hazardous waste at an LQG within your company. First, check with your state to see if it has adopted the
VSQG-LQG consolidation provisions. If your LQG location is in a different state, both states must adopt the consolidation
regulations before you may use this provision. All VSQGs and the LQG must be under the control of the same company
to participate in this consolidation option.
To begin consolidating, the LQG would notify the implementing agency that it plans to consolidate its VSQG waste at
its facility using the EPA Site ID form referenced on page 10.This notification must be submitted at least 30 days before
receiving the first shipment from one of its VSQGs.The LQG would also fill out the addendum to the Site ID form listing
the VSQGs that are participating in the program.
Ail the VSQG needs to do is mark its containers with the words "Hazardous Waste"and an indication of the hazards of the
contents. It would then ensure delivery of its waste to the LQG location, making sure it stays within the overall accumula-
tion limit for VSQGs (less than 1,000 kg of non-acute hazardous waste or 1 kg of acute hazardous waste). The LQG would
then manage the VSQG waste along with its own generated hazardous waste following all LQG requirements.
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SUMMARY OF REQUIREMENTS FOR
SMALL QUANTITY GENERATORS
If your business generates between 7 00 and 1,000 kg (220
and2,200 lbs) of hazardous waste per month, you are an
SQG and you must obtain and use an EPA identification
number. EPA and states use these 12-character numbers
to monitor and track hazardous waste activities. You will
need to use your EPA identification number when you
send waste off site to be managed.
Obtaining an EPA Identification Number
To obtain an EPA identification number, you should:
• Contact your state hazardous waste management
agency or the hazardous waste division of your EPA
regional office and ask for a copy of EPA Form 8700-
12/RCRA Subtitle C Site Identification Form"(Site ID
form). EPA regional offices are listed on page 23. (You
can also download the form and instructions with
those portions of the regulations that will help you
identify your waste at www.epa.aov/hwaenerators/
how-hazardous-waste-oenerators-transporters-and-
treatment-storaae-and-disposal.) A sample excerpt of
a completed Site ID form—showing two pages from
it—is shown on pages 11-12. Note that a few states
use a different form; in those states, you'll need to get
the appropriate form from your state agency.
• Fill in the Site ID form as shown in the example.To
complete Item 10.B, you will need to identify your
hazardous waste by its EPA Hazardous Waste Code.
(For a complete list of waste codes, consult 40 CFR
Part 261 or contact your state or regional EPA office.)
The form you receive from your state might contain
an extra sheet that provides more space for waste
codes. Complete one copy of the form for each
business site where you generate or handle hazard-
ous waste. Each site will receive its own EPA identifi-
cation number. Make sure you sign the certification in
Item 19 of the Site ID form.
• Submit the completed form to your STATE hazardous
waste contact (available at https://rcrapublic.epa.gov/
rcrainfoweb/modules/main/state contacts.html).
EPA—or the state—records the information on the form
and assigns an EPA identification number to the site
identified on your form.The EPA number stays with the
property when ownership changes. If you move your
business, you must notify EPA or the state of your new
location and submit a new form. If another business
previously handled hazardous waste at this location
and obtained an EPA identification number, you will be
assigned the same number after you have notified EPA
that you have moved to this location. Otherwise, EPA will
assign you a new identification number.
If the waste streams you generate change or you become
an LQG, you should submit a new form. In addition,
starting in 2021, SQGs must re-notify every four years
using this same form.
ELECTRONIC REPORTING OPTIONS
AVAILABLE
EPA has electronic reporting options available
for the 8700-12/Site ID form in states that have
opted to use the electronic system. Check with
your state environmental agency to see if the
electronic MyRCRAID system is available to you.
10
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EXCERPT FROM A SAMPLE RCRA SUBTITLE C SITE IDENTIFICATION FORM
OMB# 2050-0024, Expires 05/31/2020
United States Environmental Protection Agency
RCRA SUBTITLE C SITE IDENTIFICATION FORM
1. Reason for Submittal (Select only one.)
&
Obtaining or updating an EPA ID number for an on-going regulated activity that will continue for a
period of time. (Includes HSM activity)
~
Submittina as a component of the Hazardous Waste Report for (Reoortina Year)
D Site was aTSD facility and/or generator of > 1,000 kg of hazardous waste, > 1 kg of acute
hazardous waste, or > 100 kg of acute hazardous waste spill cleanup in one or more months of
the reporting year (or State equivalent LQG regulations)
~
Notifying that regulated activity is no longer occurring at this Site
~
Obtaining or updating an EPA ID number for conducting Electronic Manifest Broker activities
~
Submitting a new or revised Part A Form
2. Site EPA ID Number
V
A
P
1
2
3
4
S
(b
7
S
1
3. Site Name
General Metal Processing
4. Site Location Address
Street Address SOX Main Street
City,Town, orVillage SWiall lOWn
county: Arlington
State VA
country United States
Zip Code 3.2.34-5
5. Site Mailing Address
Q^>ame as Location Address
Street Address
City,Town, orVillage
State
Country
Zip Code
6. Site Land Type
^Private EH County EH District EH Federal EH Tribal EH Municipal EH State D Other
7. North American Industry Classification System (NAICS) Code(s) for the Site (at least 5-digit codes)
A. (Primary) 33i4
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EXCERPT FROM A SAMPLE RCRA SUBTITLE C SITE IDENTIFICATION FORM (CONTINUED)
OMB# 2050-0024, Expires 05/31/2020
EPA ID Number
V
A
P
7.
3
4
5
7
8
10. Type of Regulated Waste Activity (at your site)
Mark"Yes"or"No"for all current activities (as of the date submitting the form); complete any additional boxes
as instructed.
A. Hazardous Waste Activities
^ Y ~ N
1. Generator of Hazardous Waste—If "Yes", mark only one of the following—a, b, c
~
a. LQG
- Generates, in any calendar month (includes quantities imported by
importer site) 1,000 kg/mo (2,200 lb/mo) or more of non-acute hazardous
waste; or
- Generates, in any calendar month, or accumulates at any time, more than
1 kg/mo (2.2 lb/mo) of acute hazardous waste; or
- Generates, in any calendar month or accumulates at any time, more than
100 kg/mo (220 lb/mo) of acute hazardous spill cleanup material.
b. SQG
100 to 1,000 kg/mo (220-2,200 lb/mo) of non-acute hazardous waste and
no more than 1 kg (2.2 lb) of acute hazardous waste and no more than 100
kg (220 lb) of any acute hazardous spill cleanup material.
~
c. VSQG
Less than or equal to 100 kg/mo (220 lb/mo) of non-acute hazardous waste.
lf"Yes"above, indicate other generator activities in 2 and 3, as applicable.
~ Y ~ N
2. Short-Term Generator (generates from a short-term or one-time event and not from on-
going processes). IF'Yes", provide an explanation in the Comments section.
~ Y ~ N
3. Mixed Waste (hazardous and radioactive) Generator
~ Y ~ N
4.Treater, Storer or Disposer of Hazardous Waste—Note: A hazardous waste Part B permit
is required for these activities.
~ Y ~ N
5. Receives Hazardous Waste from Off-site
~ Y ~ N
6. Recycler of Hazardous Waste
~
a. Recycler who stores prior to recycling
~
b. Recycler who does not store prior to recycling
~ Y ~ N
7. Exempt Boilerand/or Industrial Furnace—If "Yes", markall thatapply.
~
a. Small Quantity On-site Burner Exemption
~
b. Smelting, Melting, and Refining Furnace Exemption
B. Waste Codes for Federally Regulated Hazardous Wastes. Please list the waste codes of the Federal
hazardous wastes handled at your site. List them in the order they are presented in the regulations (e.g.
D001, D003, F007, U112). Use an additional page if more spaces are needed.
P ooz
FOO
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Managing Hazardous Waste On Site
Most small businesses accumulate some hazardous waste
on site for a short period of time and then ship it off site to a
TSDF.
Accumulating Your Waste
Accumulating hazardous waste on site can pose a threat to
human health and the environment, so you may keep it only
for a short time without a RCRA hazardous waste permit.
Before shipping the waste for disposal or recycling, you are
responsible for its safe management, which includes safe
storage, appropriate labeling, safe treatment, preventing
accidents, and responding to emergencies in accordance
with federal regulations.
SQGs can accumulate no more than 6,000 kg (13,228 lbs) of
hazardous waste on site for up to 180 days without a permit.
You can accumulate this amount of waste for up to 270
days if you must transport it more than 200 miles away for
recovery, treatment, or disposal. Limited extensions may be
granted by the state director or the regional EPA administra-
tor. If you exceed these limits, you are considered aTSDF and
must obtain an operating permit. Wastes generated in small
amounts throughout your facility may be stored in satellite
accumulation areas at or nearthe point of generation of the
waste. Containers in satellite accumulation areas must be
kept closed most of the time and be marked with the words
"Hazardous Waste"and the hazards of the contents.
The total amount of waste that may be accumulated at a
satellite area is limited to 55 gallons. Once this guantity has
been exceeded, you have three calendar days to transfer the
waste to your designated central accumulation area (CAA)
(also sometimes referred to as your"180-day [or 270-day]
storage area").
Note: Different and significantly smaller guantity limits apply
to acute hazardous wastes.
SQGs must accumulate waste in tanks or containers, such
as 55-gallon drums. Your storage tanks and containers must
be managed according to EPA reguirements summarized on
page 14.
Treating Your Waste to Meet the Land Disposal
Restrictions
Most hazardous wastes may not be land disposed unless they
meet "treatment standards." The Land Disposal Restrictions
(LDR) program reguires that the waste be either (a) treated
to reduce the hazardous constituents to levels set by EPA or
(b) treated using a specific technology. It is your responsibility
SUMMARY OF MANAGEMENT
REQUIREMENTS
• Accumulate wastes according to limits
established by EPA for SQGs.
• Follow the storage and handling procedures
reguired by EPA for SQGs.
• Follow EPA reguirements for eguipment testing
and maintenance, access to communications
or alarms, aisle space, and emergency
arrangements with local authorities.
to ensure that your waste meets LDR treatment standards
before it is land disposed (see page 19 for a description of
reguired LDR notices). Most SQGs typically have aTSDF treat
their waste. If you choose to treat your waste yourself to meet
LDR treatment standards, there are additional reguirements
including waste analysis plans, notifications, and certifications.
To learn about these reguirements, contact your state agency
or EPA regional office and consult 40 CFR Part 268.
Preventing Accidents
Whenever you store hazardous waste on site, you must
minimize the potential risks from fires, explosions, or other
accidents.
Any SQG that stores hazardous waste on site must have:
• An internal communications or alarm system capable of
providing immediate emergency instruction (voice or
signal) to all personnel.
• A device, such as a telephone (immediately available at
the scene of operations) or a handheld, two-way radio,
capable of summoning emergency assistance from local
police and fire departments or emergency response
teams.
• Portable fire extinguishers, fire-control devices (including
special extinguishing eguipment using foam, inert gas, or
dry chemicals), spill-control materials, and decontamina-
tion supplies.
• Water at adeguate volume and pressure to supply water
hose streams, foam-producing eguipment, automatic
sprinklers, or water spray systems.
You must test and maintain all eguipment to ensure proper
operation. Allow enough aisle space for the unobstructed
movement of personnel, fire protection eguipment, spill-con-
trol eguipment, and decontamination eguipment to any area
of facility operation. Attempt to secure arrangements with fire
13
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• Mark each container with the words "Hazardous
Waste,"the date that the waste was generated,
and the hazards of the contents of the container
(e.g., ignitable, corrosive, toxic, or reactive or
another nationally recognized hazard label).
• Use a container made of—or lined with—a
material that is compatible with the hazardous
waste to be stored.This will prevent the waste
from reacting with or corroding the container.
• Keep all containers holding hazardous waste
closed during storage, except when adding
or removing waste. Do not open, handle, or
store (e.g., stack) containers in a way that might
rupture them, cause them to leak, or otherwise
fail
• Inspect container storage areas at least weekly.
Look for leaks and for deterioration caused by
corrosion or other factors.
• Keep the containers in good condition. If a
container leaks, put the hazardous waste in
another container, or contain it in some other
way that complies with EPA regulations.
• Take precautions to avoid mixing incompatible
wastes or materials in the same container to
prevent dangerous situations.
• Mark each tank with the words "Hazardous
Waste,"the date that the waste was generated,
and the hazards of the contents of the tank (e.g.,
ignitable, corrosive, toxic, or reactive or another
nationally recognized hazard label).
• Store only waste that will not cause the tank
or the inner liner of the tank to rupture, leak,
corrode, or fail.
• Equip tanks with an automatic waste feed with a
waste feed cutoff system, or a bypass system for
use in case of a leak or overflow.
• Inspect discharge control and monitoring
equipment and the level of waste in uncovered
tanks at least once each operating day. Inspect
the tanks and surrounding areas for leaks or
other problems (such as corrosion) at least
weekly.
• Use the National Fire Protection
Association's (NFPA's) buffer zone require-
ments for covered tanks containing ignitable
or reactive wastes.These requirements specify
distances considered to be safe buffer zones
forvarious ignitable or reactive wastes. You can
reach the NFPA at 800-344-3555.
• Do not mix incompatible wastes or materials
unless precautions are taken to prevent danger-
ous situations.
• Do not place ignitable or reactive wastes in
tanks unless certain precautions are taken.
• Provide at least 60 centimeters (2 feet) of
freeboard (space at the top of each tank) in
uncovered tanks, unless the tank has a contain-
ment structure, a drainage control system, or a
standby tank with adequate capacity.
14
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TIP
It is a good practice never to mix wastes. Mixing wastes
can create an unsafe work environment and potentially
result in more costly disposal.
departments, police, emergency response teams, equipment
suppliers, and local hospitals, as appropriate, to provide
emergency services. Ensure that personnel handling hazard-
ous waste have immediate access to an alarm or emergency
communications device.
You are not required to have a formal personnel training
program, but you must ensure that employees handling
hazardous waste are familiar with proper handling and emer-
gency procedures. In addition, you must have an emergency
coordinator on the premises or on call at all times, and have
basic facility safety information readily accessible.
Responding to Emergencies
Although EPA does not require SQGs to have written con-
tingency plans, you should be prepared for an emergency
at your facility. You should also be prepared to answer a set
of "what if" questions. Forexample:"What if there is a fire in
the area where hazardous waste is stored?" or"What if I spill
hazardous waste, or one of my hazardous waste containers
leaks?" In case of a fire, explosion, or toxic release, having
such a plan provides an organized and coordinated course
of action. SQGs should establish and adhere to basic safety
guidelines and have up-to-date response procedures to
follow in the event of an emergency.
Worksheets 1 and 2 (on page 16) can help you set up these
procedures.The information on Worksheet 1 must be posted
near your phone. You must ensure that employees are familiar
with these procedures.
IF YOU THINK YOU HAVE AN EMERGENCY,
IMMEDIATELY CALL 911 AND THE
NATIONAL RESPONSE CENTER AT
800-424-8802
In the event of a fire, explosion, or other release of
hazardous waste that could threaten human health
outside the facility, or if you think that a spill has
reached surface water, call the National Response
Center to report the emergency.The Response
Center will evaluate the situation and help you make
appropriate emergency decisions. You may find that
the problem you faced was not a true emergency, but
it is better to call if you are not sure. Serious penalties
exist for failing to report emergencies or releases of
hazardous wastes.
15
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Worksheet 1: Fill in and post this information next to your telephone.
EMERGENCY RESPONSE INFORMATION
Emergency Coordinator
Name:
Spill-Control Materials
Location(s):
Telephone:
Fire Extinguisher
Location(s):
Fire Alarm (if present)
Location(s):
Fire Department
Telephone:
Worksheet 2: Fill in and post this information next to your telephone. Make sure all employees are familiar with its contents.
EMERGENCY RESPONSE PROCEDURES
In the event of a spill:
Contain the flow of hazardous
waste to the extent possible, and
as soon as is possible, clean up
the hazardous waste and any
contaminated materials or soil.
In the event of a fire:
Call the fire department and, if safe,
attempt to extinguish the fire using
a fire extinguisher.
In the event of a fire, explosion, or
other release that could threaten
human health outside the facility,
or if you know that the spill has
reached surface water:
Call the National Response Center at
its 24-hour number (800-424-8802).
Provide the following information:
Our company name:
Our address:
Our U.S. EPA identification number:
Date of accident:
Time of accident:
Type of accident (e.g., spill or fire):
Quantity of hazardous waste involved: _
Extent of injuries, if any:
Estimated quantity and disposition of recovered materials, if any:
16
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WASTE MINIMIZATION: THE KEY TO BETTER WASTE MANAGEMENT
The easiest, most cost-effective way to manage any waste is not to generate it in the first place. You can decrease the
amount of hazardous waste your business produces by developing a few "good housekeeping" habits. Good housekeep-
ing procedures generally save businesses money, and they prevent accidents and waste.To help reduce the amount of
waste you generate, try the following practices at your business.
• Do not mix wastes. Do not mix non-hazardous waste with hazardous waste. Once you mix anything with a listed
hazardous waste, the whole batch becomes hazardous. Mixing waste can also make recycling very difficult, if not
impossible. A typical example of mixing wastes would be putting non-hazardous cleaning agents in a container of
used hazardous solvents.
• Change materials, processes, or both. Businesses can save money and increase efficiency by replacing a material or
process with another that produces less waste. For example, you could use plastic blast media for paint stripping of
metal parts rather than conventional solvent stripping. In addition, some companies have taken waste minimization
actions such as using fewer solvents to do the same job, using solvents that are less toxic, or switching to a deter-
gent solution.
• Recycle and reuse manufacturing materials. Many companies routinely put useful components back into produc-
tive use rather than disposing of them. Items such as oil, solvents, acids, and metals are commonly recycled and
used again.
• Safely store hazardous products and containers. You can avoid creating more hazardous waste by preventing spills
or leaks. Store hazardous products and waste containers in secure areas, and inspect them often for leaks. When
leaks or spills occur, materials used to clean them up also become hazardous waste.
• Make a good faith effort. SQGs do not have to document their waste minimization activities or create a waste
minimization plan. You do, however, need to certify on your manifests that you have made a good faith effort to
minimize waste generation when you send yourwaste off site.
Shipping Waste Off Site
When shipping waste off site, SQGs must follow certain
procedures to ensure safe transport and proper management
of the waste.
Choosing a Treatment, Storage, and Disposal
Facility
SQGs may only send their waste to regulated TSDFs and/
or recyclers. Most regulated TSDFs and recyclers will have
permits from the state or EPA. Some, however, may operate
under other regulations that do not require a permit.
Check with the appropriate state authorities to be sure the
facility you choose has any necessary permits. All TSDFs and
recyclers must have EPA identification numbers. Ensuring the
good standing of the destination facility is important because
hazardous waste generators can retain liability for waste mis-
managed at aTSDF under RCRA (the Resource Conservation
and Recovery Act) and Superfund (the Comprehensive
Emergency Response, Compensation, and Liability Act, or
CERCLA).
Preparing Waste Shipments
SQGs must properly package, label, and mark all hazardous
waste shipments, and placard the vehicles in which
these wastes are shipped following Department of
Transportation (DOT) regulations. Most small businesses
use a commercial transporter to ship hazardous waste.These
transporters can advise you on specific requirements for
placarding, labeling, marking, and packaging; however, you
remain responsible for compliance. For more information,
17
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consult the DOT regulations (49 CFR Parts 172 and 173) or
contact the DOT hazardous materials information line at
800-467-4922 or infocntr@dot.gov.
Preparing Hazardous Waste Manifests
The Hazardous Waste Manifest System is a set of forms,
reports, and procedures designed to seamlessly track
hazardous waste from the time it leaves the generator until it
reaches the off-site waste management facility that will store,
treat, or dispose of the hazardous waste. The system allows
the waste generator to verify that its waste has been properly
delivered and that no waste has been lost or unaccounted for
in the process.
The key component of this system is the Uniform Hazardous
Waste Manifest, a multipart form prepared by most gener-
ators that transport hazardous waste for off-site treatment,
recycling, storage, or disposal.The manifest is reguired by
both DOT and EPA. When completed, it contains information
on the type and guantity of the waste being transported,
instructions for handling the waste, and signatures of all
parties involved in the off-site treatment, recycling, storage,
or disposal of the waste. Each party must keep a copy of the
manifest.This process ensures critical accountability through-
out transportation and disposal. Once the waste reaches its
destination, the receiving facility returns a signed copy of
the manifest to the generator, confirming that the waste has
been received.
Land Disposal Restriction Reporting
Requirements
Regardless of where the waste is being sent, the initial
shipment of waste subject to LDRs must be sent to a receiv-
ing TSDF or recycler along with an LDR notice. You must send
E-MANIFEST AVAILABLE NATIONWIDE
Electronic manifests are now an option everywhere!
e-Manifest launched nationwide on June 30, 2018. All
generators have the option of creating and submitting
their hazardous waste manifests electronically in
e-Manifest. Generators can continue to use a paper
manifest, but it is cheaper and faster to submit the
uniform manifest form electronically.To use e-Manifest,
generators must have an EPA identification number
(see page 10 for how to get your EPA ID number) and
register with e-Manifest. For more information and to
register for e-Manifest, go to www.epa.gov/e-Manifest.
an additional LDR notice if your waste or receiving facility
changes.This notice must provide information about your
waste, such as the EPA hazardous waste code and the LDR
treatment standard. The purpose of this notice is to let the
TSDF know that the waste must meet treatment standards
before it is land disposed.There is no EPA-reguired form for
this notice, but yourTSDF may provide a form for you to use.
A certification may also be reguired in specific situations.
Contact your state agency or EPA regional office, and consult
40 CFR Part 268 for help with LDR notification and certifica-
tion reguirements.
Export Notification
If you choose to export your hazardous waste, you must
notify EPA at least 60 days before the intended date of
shipment to reguest consent to export. Export is prohibited
until you receive an EPA "Acknowledgement of Consent" letter
documenting consentfrom the country of import and any
countries of transit. For more information on how to obtain
the consent to export hazardous waste and comply with
additional hazardous waste export reguirements, please go to
www.epa.gov/hwgenerators/information-exporters-resource-
conservation-and-recoverv-act-rcra-hazardous-waste.
Closure
When you close your facility, you must ensure that all
hazardous waste has been removed from your hazardous
waste containers and/or tanks, discharge control eguipment,
and discharge confinement structures. In addition, any
contamination you might have caused must be cleaned
up and managed under all applicable hazardous waste
regulations.
SUMMARY OF SHIPPING REQUIREMENTS
• Package, label, and mark your shipment, and
placard the vehicle in which yourwaste is shipped
as specified in DOT regulations.
• Prepare a hazardous waste manifest to accompany
yourshipment.
• Include a notice and certification with the first
waste shipment.
• Ensure the proper management of any hazardous
waste you ship (even when it is no longer in your
possession).
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CHOOSING A TRANSPORTER, TSDF/RECYCLER, OR WASTE MANAGEMENT COMPANY
As a smali business,.you may not have the expertise to perform
some or ali the duties necessary to comply with the hazardous
waste regulations. Because the consequences of non-compliance
can be significant, you may decide to hire a professional waste
management company. Depending on how complicated your
waste generation is and on your level of in-house expertise, you
may decide to contract separately with a transporter and aTSDF'/
recycleror hire a fuli-service waste management company that
handles all your hazardous waste obligations. Once you have
decided which path meets your needs, it is important to select your
vendors carefully—you'll ultimately be responsible for the proper
management of your hazardous waste even after it has left your site.
Asking the right questions and conducting thorough due diligence
in advance can add to your confidence that your hazardous waste
will be managed safely, effectively, and in compliance with the regulations:
• Can the company give you a clear description of its business and compliance history?
• Can all recyclers describe their processes and procedures for recycling, reuse, or resale?
• Are the vendor's waste operations regularly audited by a third party and can you access those reports?
In addition, for help in choosing a vendor, check with the following sources:
• References from business colleagues who have used a specific waste management company.
• Trade associations for your industry that might keep files on companies that handle hazardous waste.
• The Better Business Bureau or local Chamber of Commerce, which keep records of registered complaints.
• Your implementing agency, which can tell you whether the vendor has an EPA identification number and a
permit, if required. The Envirofacts website publishes facility information, including types and quantities of waste
managed and violations assessed at www.epa.aov/enviro.
Once you have selected a hazardous waste management partner, ongoing communication can ensure continued
compliance. Remember these points when overseeing the management of your waste, no matter who performs each
step in the process:
• Making a correct hazardous waste determination is critical—you know your waste best, so pay attention when a
vendor suggests how to classify your waste.
• Make sure the waste handier you have hired is fully informed regarding the chemical and physical attributes of
your waste. If something changes about your process or your waste, immediately share that information with
those managing the waste. Even the smallest detail may be important.
• Know where your hazardous waste goes when it leaves your site. Understand the path your waste is taking to final
disposal or recycling.
• Make sure your records are complete and accurate, including when created by a third party.
You can use the information you have learned in this Guide to focus your discussions about your waste management.
Continue toaskyour providers questions about their practices and procedures. Remember, you are ultimately respon-
sible forthe proper disposal ofthe hazardous waste.
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SUMMARY OF REQUIREMENTS FOR
LARGE QUANTITY GENERATORS
If you are an LQG (generating more than 1,000 kg [2,200 lbs] per month), you must comply with the full set of hazardous
waste generator regulations. This table summarizes the federal LQG requirements; it is only a summary and does not
include all LQG requirements. For more details, see 40 CFR Part262. Be sure to check with your state as well, because some
states have additional or more stringent requirements than the federal government.
LQG Requirements
Summary
Hazardous Waste Determination
(40 CFR 262.11)
Generator Category
Determination
(40 CFR 262.13)
Identify all hazardous wastes you generate. Count the amount of hazardous waste you
generate per month to determine your generator category (e.g., LQG).
EPA Identification Numbers
(40 CFR 262.18)
Obtain a copy of EPA Form 8700-12, fill out the form, and send it to your state. An EPA
identification number for your location will be returned to you.
Prepare Hazardous Waste for
Shipment Off Site
(40 CFR 262.30-262.33)
Package, label, mark, and placard wastes following Department ofTransportation require-
ments. Ship waste using a hazardous waste transporter.
The Manifest (40 CFR Part 262
Subpart B and 262.42)
Ship waste to a hazardous waste treatment, storage, disposal, or recycling facility. Ship
hazardous waste off site using the manifest system (EPA Form 8700-22) or state equivalent.
Managing Hazardous Waste On
Site
(40 CFR 262.17 and Part 262
Subpart M)
Accumulate waste for no more than 90 days without a permit. Accumulate waste in
containers, tanks, drip pads, or containment buildings. Comply with specified technical
standards for each unit type. Complete a contingency plan and comply with other
emergency planning and preparedness requirements.
Recordkeeping and Biennial
Report
(40 CFR 262.40-262.41)
Retain specified records for three years. Submit biennial report by March 1 of even
numbered years covering generator activities for the previous year.
Comply with Land Disposal
Restrictions (40 CFR Part 268)
Ensure that wastes meet treatment standards prior to land disposal. Send notifications and
certifications toTSDF as required. Maintain waste analysis plan if treating on site.
Export/Import Requirements
(40 CFR Part 262 Subpart H)
Follow requirements for exports and imports, including notification of intent to export and
acknowledgement of consent from receiving country.
Air Emissions
(40 CFR Part 265 Subparts AA, BB,
and CC)
If applicable, use various monitoring and control mechanisms to:
Control volatile organic compound (VOC) emissions from hazardous waste manage-
ment activities.
Reduce organic emissions from process vents associated with certain recycling
activities and equipment that is in contact with hazardous waste that has significant
organic content.
Control VOCs from hazardous waste tanks, surface impoundments, and containers
using fixed roofs, floating roofs, or closed-vent systems routed to control devices.
Closure
(40 CFR 262.17)
Complete closure notification. Decontaminate and remove all contaminated equipment,
structures, and soil, and minimize the need for further maintenance of your site. Meet
unit-specific closure standards for containers, tanks, containment buildings, and drip pads.
20
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WHERE TO GET MORE HELP
For more help understanding the hazardous waste
regulations applicable to you, contact your state
hazardous waste agency. Other assistance resources
include the EPA website (www.epa.aov/hwaeneratorsl EPA
headquarters and other federal resource centers (page 22),
or your EPA regional office (page 23).
Other EPA resources include:
• The Frequent Questions Knowledge Base, where
there are Q&As on various hazardous waste
topics, including generators and hazardous waste
identification: https://www.epa.aov/hwaenerators/
freguent-guestions-hazardous-waste-aenerators
• The RCRAOnline website, where there are interpreta-
tive memos on various RCRA topics: https://rcrapublic.
epa.gov/rcraonline/.
Also see other potentially relevant sections of the CFR:
• 40 CFR Part 761 (handling PCBs, or polychlorinated
biphenyls)
• 40 CFR Part 372 (Toxics Release Inventory reporting)
• 40 CFR Part 403 (domestic sewage waste disposal
reporting)
• 49 CFR Parts 171 -180 (shipping hazardous materials)
RCRA IN FOCUS BOOKLETS AVAILABLE
RCRA in Focus is a series of short informational booklets that describe the RCRA regulations as they apply to specific
industry sectors.The documents explain what RCRA is, who is regulated, and what hazardous waste is; provide a
sample life cycle of a RCRA waste in each industry; include a guick reference chart of all applicable RCRA regulations
and a series of waste minimization suggestions forvarious specific industrial processes; and provide information on
other relevant environmental laws, contacts, and resources.
Individual issues of RCRA in Focus have been written forthe following industries:
• Construction, demolition, and renovation (EPA 530-K-04-005)
• Dry cleaning (EPA 530-K-99-005) (also available in Korean)
• Furniture manufacturing and refinishing (EPA 530-K-03-005)
• Leather manufacturing (EPA 530-K-00-002)
• Motor freight and railroad transportation (EPA 530-K-00-003) {also available in Spanish)
• Photo processing (EPA 530-K-99-002)
• Printing (EPA 530-K-97-007) (also available in Spanish)
• Textile manufacturing (EPA 530-K-02-028)
• Vehicle maintenance (EPA 530-K-99-004) {also available in Spanish)
You can view the RCRA in Focus documents online at www.epa.gov/hwgenerators/resource-conservation-and-
recoverv-act-rcra-focus-hazardous-waste-generator-guidance. EPA also provides compliance assistance on a sector-
by-sector basis in order to efficiently reach facilities with similar operations, processes, or practices:
www.epa.gov/regulatorv-information-sector.
21
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EPA and Other Federal Resource Centers
Environmental Protection Agency Headquarters (Washington, DC)
EPA Small
Business
Ombudsman
Hotline
EPA Small Business Ombudsman
1200 Pennsylvania Ave, NW
Washington, DC 20460
800-368-5888
or
202-566-1970
Web: www.epa.aov/
resources-small-businesses/
Helps private citizens, small businesses, and
smaller communities with guestions on all
program aspects within EPA
asbestos-small-business-ombudsman
RCRA Dockets
EPA Docket Center
WJCWest Building, Rm 3334
1301 Constitution Ave, NW
Washington, DC 20004
202-566-0270
Email: rcra-docket@epa.aov
Web: www3.epa.aov/enviro/facts/
rcrainfo/search.html
Provides documents involved in the differ-
ent stages of Office of Land and Emergency
Management (OLEM) rulemakings
Pollution
Protection
Information
Clearinghouse
(PPIC)
EPA PPIC (7409M)
1200 Pennsylvania Ave, NW
Washington, DC 20460
202-566-0799
Email: ppic@epa.aov
Web: www.epa.aov/p2/
pollution-prevention-resources#ppic
Provides references and referrals on
pollution prevention to help reduce and
eliminate industrial pollutants through
education and public awareness
EPA National
Library
EPA Headguarters and Chemical
Libraries (MC3404T)
1200 Pennsylvania Ave, NW
Washington, DC 20460
202-566-0556
Email: hgchemlibraries@>epa.aov
We b: www.e pa.a ov/l i b ra ries/cata loa
Maintains environmental reference mate-
rials for EPA staff and makes information
resources accessible to the public
Department of Transportation (Washington, DC)
Hazmat
Information
Center
Standards and Rulemaking
Division
U.S. DOT/PHMSA (PHH-10)
1200 New Jersey Ave, SE
East Building, 2nd Floor
Washington, DC 20590
800-467-4922
or
202-366-4488
Email: infocntr@dot.aov
Web: www.phmsa.dot.aov/standards-
rulemakina/hazmat/hazardous-
materials-information-center
Answers guestions on matters related to
DOT's hazardous materials transportation
regulations
22
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EPA Regional Offices
Region
States Represented
Address
Main Phone Number(s)
Regional Library Phone
Number/Email
EPA Region 1
CT, MA, ME, NH, RI,VT
5 Post Office Square, Suite 100
Boston, MA 02109-3912
888-372-7341
617-918-1990/
rl librarv(5>epa.aov
EPA Region 2
NJ, NY, Puerto Rico, Virgin Islands
290 Broadway
New York, NY 10007-1866
877-251-4575
212-637-3185/
reaion2 librarv(5>epa.aov
EPA Region 3
DC, DE, MD, PA, VA, WV
1650 Arch Street
Philadelphia, PA 19103-2029
215-814-5122 or
800-438-2474 in Region 3
215-814-5254/
libra rv-rea3@epa.aov
EPA Region 4
AL, FL, GA, KY, MS, NC, SC,TN
Sam Nunn Atlanta Federal Center
61 Forsyth Street SW
Atlanta, GA 30303-8960
800-241-1754
404-562-8190/
r4-librarv(5>epa.aov
EPA Region 5
IL, IN, Ml, MN, OH, Wl
Ralph Metcalfe Federal Building
77 West Jackson Boulevard
Chicago, IL 60604
312-353-2000
312-886-6822/
libra rv.r05@epa.aov
EPA Region 6
AR, LA, NM,OK,TX
Renaissance Tower
1201 Elm Street
Dallas,TX 75270
214-665-2760 or
800-887-6063 in Region 6
214-665-6424/
library reaion6@epa.aov
EPA Region 7
IA, KS, MO, NE
11201 Renner Boulevard
Lenexa, KS 66219
913-551-7003 or
800-223-0425 in Region 7
913-551-7979/
r7-librarv@epa.aov
EPA Region 8
CO, MT, N D, S D, WY, UT
1595 Wynkoop Street
Denver, CO 80202-1129
303-312-6312 or
800-227-891 7 in Region 8
303-312-7226/
libra rv-rea8@epa.aov
EPA Region 9
American Samoa, AZ, CA, Guam,
HI, Marshall Islands, Northern
Mariana Islands, NV
75 Hawthorne Street
San Francisco, CA 94105
415-947-8000 or
866-372-9378 in Region 9
415-947-4406/
libra rv-rea9@epa.aov
EPA Region 10
AK, ID, OR, WA
Park Place Building
1200 6th Avenue
Seattle, WA 98101
206 553-1200 or
800-424-4372 in Region 10
206-553-1289/
Iibrarv-rea10@epa.aov
23
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Worksheet 3: These questions are geared toward the federal requirements for SQGs but may be helpful for other hazardous
waste generators. Use them to help prepare for a visit from a federal, state, or local agency.
r — — — —
Yes No
~ ~
Do you have documentation on the amount and kinds of hazardous waste that you generate
and on how you determined that they are hazardous?
Do you have copies of completed manifests used to ship your hazardous wastes over the past 3
years?
~ ~
~ ~ Do you have a U.S. EPA identification number?
~ ~ Do you ship wastes off site?
~ ~ If so, do you know the name of the transporter and the designated TSDF/recycler that you use?
~ ~
~ ~ Are they filled out correctly?
~ ~ Have they been signed by the designated TSDF/recycler and transporter?
~ ~
~ ~ Is your hazardous waste stored in proper containers or tanks?
~ ~ Are the containers or tanks properly dated and marked?
~ ~ Have you complied with the handling requirements described in this handbook?
~ ~ Have you designated an emergency coordinator?
~ ~ Have you posted emergency telephone numbers and the location of emergency equipment?
~ ~
~ ~ Do you understand when you need to contact the National Response Center?
If you have not received your signed copy of the manifest from the TSDF/recycler, have you filed
an exception report?
Are your employees thoroughly familiar with proper waste handling and emergency proce-
dures?
Do you store your hazardous waste for no more than 180 days, or 270 days if you ship your
waste more than 200 miles?
L — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — — —
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ABBREVIATIONS AND DEFINITIONS
This section explains terms used throughout this
guide. Terms italicized below also appear in the federal
hazardous waste regulations. (Note: some of the
regulatory terms are more detailed in the regulations.)
acute hazardous waste
Specific hazardous wastes that are particularly dangerous to
human health and, therefore, are regulated more stringently
at lower volumes. Certain wastes listed in 40 CFR 261.31 with
the assigned hazard code of(H) and the P hazardous waste
codes listed in 40 CFR 261.33(e) are acute hazardous wastes.
(40 CFR 260.10)
byproduct
A material that is not one of the primary products of a produc-
tion process. Examples of byproducts are process residues such
as slags or distillation column bottoms. (40 CFR 261.1 (c))
CAA (central accumulation area)
An onsite hazardous waste accumulation area with waste
accumulating in units subject to SQG orLQG requirements. (40
CFR 260.10)
CFR (Code of Federal Regulations)
A codification of the general and permanent rules pub-
lished in the Federal Register by the executive departments
and agencies of the federal government. The CFR is
divided into 50"titles,"which represent broad areas subject
to federal regulation. Each title is divided into chapters,
which usually bearthe name ofthe issuing agency.
commercial chemical product
A chemical substance that is manufactured or formulated for
commercial or manufacturing use. (40 CFR 261.33(d))
container
Any portable device in which a material is stored, transported,
treated, disposed of, or otherwise handled. (40 CFR 260.10)
DOT (Department of Transportation)
The federal agency that oversees all national transpor-
tation systems and regulates the transport of hazardous
materials.
elementary neutralization unit
A tank, tank system, container, transport vehicle, or vessel
(including ships) that is designed to contain and neutralize
corrosive waste. (40 CFR 260.10)
implementing agency
The EPA regional office or state or local agency responsible
for enforcing the hazardous waste regulations.
incompatible waste
A hazardous waste that can cause corrosion or decay of
containment materials, or is unsuitable for comingling
with another waste or material because a dangerous
reaction might occur. See 40 CFR Part 265 Appendix Vfor
examples.
LDR (Land Disposal Restrictions)
The LDR program ensures that toxic constituents present
in hazardous waste are properly treated before that waste
is disposed of in the land (such as in a landfill).
LQG (large quantity generator)
A business that generates more than 1,000 kg (2,200 lbs) per
month of hazardous waste or 1 kg (2.2 lbs) per month of acute
hazardous waste. (40 CFR 260.10)
NFPA (National Fire Protection Association)
NFPA is a nonprofit organization devoted to eliminating
death, injury, property, and economic loss due to fire,
electrical, and related hazards. NFPA has a code of stan-
dards for storing hazardous wastes.
non-acute hazardous waste
All hazardous wastes that are not acute hazardous waste. (40
CFR 260.10)
POTW (publicly owned treatment works)
A municipal wastewater treatment plant that receives
wastewater through the public sewer from households, office
buildings, factories and industrial facilities, and other places
where people live and work. (40 CFR 260.10)
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reclaimed material
Material that is regenerated or processed to recover a usable
product. Examples are the recovery of lead values from spent
batteries and the regeneration of spent solvents. (40 CFR 261.1 (c))
recovered material
A material or byproduct that has been recovered or diverted
from solid waste. Does not include materials or byproducts
generated from, and commonly used within, an original
manufacturing process.
recycled material
A material that is used, reused, or reclaimed. (40 CFR 261.1(c))
reused material
A material that is used as an ingredient in an industrial process
to make a product, or as an effective substitute for a commercial
product. (40 CFR 261.1(c))
SDS (Safety Data Sheet)
A detailed technical bulletin, prepared by a chemical's manu-
facturer or importer, about the hazards of that chemical. Your
supplier must send you an SDS when the chemical is first
shipped and any time it updates the SDS with new, significant
information about the hazards. SDSs include information
about components and contaminants, including exposure
limits, physical data, fire and explosion hazard, toxicity, and
health hazard data.They also discuss emergency and first aid
procedures, information about storage and disposal, and spill
or leak procedures. However, an SDS may not have enough
information to make a proper hazardous waste determi-
nation. NOTE: SDSs were previously called MSDSs (Material
Safety Data Sheets).
sludge
Any solid, semi-solid, or liquid waste generated from a municipal,
commercial, or industrial wastewater treatment plant, water
supply treatment plant, or air pollution control facility, exclusive
of the treated effluent from a wastewater treatment plant. (40
CFR 260.10)
spent material
Any material that has been used and, as a result of contamina-
tion, can no longer serve the purpose for which it was produced
without first being processed. (40 CFR 261.1 (c))
SQG (small quantity generator)
A business that generates between 100 and 1,000 kg (220 and
2,200 lbs) per month of hazardous waste and less than 1 kg (2.2
lbs) per month of acute hazardous waste. (40 CFR 260.10)
still bottom
Residue or byproduct of a distillation process such as solvent
recycling.
tank
A stationary device designed to contain an accumulation of
hazardous waste and made primarily of non-earthen materials
(e.g., wood, concrete, steel, plastic). (40 CFR 260.10)
TCLP (Toxicity Characteristic Leaching Procedure)
A testing procedure used to determine whether a waste is
hazardous.The procedure identifies waste that might leach
hazardous constituents into ground water if improperly
managed.
totally enclosed treatment facility
A facility for the treatment of hazardous waste that is directly
connected to an industrial production process and that is
constructed and operated to prevent the release of hazardous
waste into the environment during treatment. An example is a
pipe in which waste acid is neutralized. (40 CFR 260.10)
TSDF (treatment, storage, and disposal facility)
A facility that treats, stores, or disposes of hazardous waste.
TSDFs have specific reguirements under RCRA, including
obtaining a RCRA permit.
VOC (volatile organic compound)
VOCs are highly evaporative organic gases that can be
produced during the manufacture or use of chemicals such
as paints, solvents, and cleaners. Various pollution control
devices can prevent the release of VOCs both outdoors and
indoors.
VSQG (very small quantity generator)
A business that generates less than 100 kg (220 lbs) per month
of hazardous waste or less than 1 kg (2.2 lbs) per month of acute
hazardous waste. (40 CFR 260.10)
wastewater treatment unit
A tank or tank system that is part of a wastewater treatment
facility subject to regulation under either Section 402 or 307(b)
of the Clean Water Act, and that treats or stores an influent
wastewater that is hazardous waste, or that treats or stores a
wastewater treatment sludge that is hazardous. (40 CFR 260.10)
26
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27
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£% United States
Environmental Protection
Agency
Official Business
Penalty for Private Use, $300
October 2019
EPA 530-K-19-001
www.epa.aQV/hwaenerators/manaaina-vour-hazardous-waste-auide-smali-businesses
Printed on 100% post-consumer recycled fiber.
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