SUMMARY OF REQUIREMENTS FOR
VERY SMALL QUANTITY
GENERATORS (VSQGs)
If you generate no more than 100 kg (220 lbs) of hazardous waste and no more than 1 kg (2.2 lbs)
of acute hazardous waste per month, you are a VSQG. As a VSQG, you must
i	comply with three basic waste management requirements.
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 or 1 kg (2.2 lbs) of acute hazardous waste
on site at anytime. 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
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 hazardous wastes such as batteries,
recalled and collected pesticides, mercury-containing
thermostats and other equipment, mercury-containing
lamps, or aerosol cans.
STATE REQUIREMENTS
Some states have additional requirements forVSQGs. For
example, some states require VSQGs to follow some of
the Small Quantity Generator (SQG) requirements, such
as obtaininq EPA identification numbers or complying
with storaqe standards. See paqe 13 of Managing Your
Hazardous Waste: A Guide for Small Businesses
(www.epa.aov/hwaenerators/manaaina-vour-hazardous-
waste-auide-small-businesses) for SQG storaqe
requirements.
Full
Half
Empty
For a typical liquid hazardous waste, 100 kg (220 lbs)
equals about half of a 55-gallon drum.
•	A Large Quantity Generator (LQG) under the control of
the same company as the VSQG, provided the VSQG
marks its containers with the words"Hazardous Waste"
and the hazards of the container's contents (e.g., using
the words ignitable, corrosive, toxjc, or reactive or
another nationally recognized hazard label).
•	For hazardous waste pharmaceuticals, a reverse
distributor or healthcare facility operating under
the appropriate sections of the Hazardous Waste
Pharmaceuticals Rule in 40 CFR Part 266 Subpart P.
•	For airbag waste, an airbag waste collection facility
or designated facility operating under 40 CFR
section 261.4(J).
www.epa.gov/hwgenerators
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BEST PRACTICE
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 confirm that
the facility fits into one of the bulleted categories listed on
front page. Make sure to document your efforts to confirm
these facts in your records.
WASTE CONSOLIDATION FROM VSQGS
If you areaVSQGthatis 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 your
VSQG hazardous waste at an LQG within your company. First,
check with your state to see if it has adopted theVSQG-
LQG consolidation provision from EPA's 2016 Generator
Improvements Rule. 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.This notification
must be submitted at least 30 days before receiving the first
shipmentfrom 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.
All the participating VSQG needs to do is mark its containers
with the words "Hazardous Waste"and proper 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 accumulation 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.
RESOURCES
•	Main Hazardous Waste Generators webpage: www.epa,gov/hwaenerators
•	Site ID Form: www.epa.gov/hwaenerators/how-hazardous-waste-aenerators-transporters-and-treatment-storaae-
and-disposal
•	Managing Your Hazardous Waste: A Guide for Small Businesses: www.eDa.gov/hwoenerators/manaoing-vour-
hazardous-waste-auide-small-businesses
•	Hazardous Waste Generator Regulations: www.epa.oov/hwoenerators/hazardous-waste-oenerator-reoulatorv-
summarv
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July 2020
EPA 530-F-20-002
www.epa.gov/hwgenerators

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