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HAZARDOUS WASTE REQUIREMENTS FOR
LARGE QUANTITY GENERATORS (LQGs)


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If you are an LQG of hazardous waste, you must comply with the full set of federal hazardous
waste generator regulations. You are considered an LQG if you generate more than 1,000 kg
(2,200 lbs) of non-acute hazardous waste or more than 1 kg (2.2 lbs) of acute hazardous waste
per calendar month. To assist your business in learning about these requirements, the U.S.
Environmental Protection Agency (EPA) has prepared this summary fact sheet.
This is only a summary and does not include all of the LQG requirements.
For a more detailed discussion of some of these issues,
you can refer to EPA's hazardous waste generator website
(www.epa.aov/hwaenerators). Be sure to check with your
state hazardous waste agency as well, as some states have
additional or more stringent requirements than the federal
government.
Identifying the Hazardous Wastes You
Generate
40 CFR 262.1] and Part 268
At the point of generation, before dilution or mixing, you
must determine if any of the solid wastes you generate
are hazardous so that you will be able to manage, report,
and track them properly. It is important to be accurate
when making a hazardous waste determination. Hazardous
wastes can be:
•	Listed wastes. These wastes will appear on one of four
lists published in 40 CFR Part 261 Subpart D.
•	Characteristic wastes. Certain wastes are considered
hazardous if they are ignitable, corrosive, reactive, or
toxic (see 40 CFR Part 261 Subpart C),
To determine if your wastes exhibit a characteristic, you may
use EPA-approved test methods or apply your knowledge of
the waste. To determine ifyourwastes are listed hazardous
wastes, you must apply your knowledge of the waste. If
waste is to be land disposed, you must determine if your
wastes exhibit any characteristics, even if they are listed
wastes. Under the Land Disposal Restrictions (LDRs), most
hazardous wastes may not be land disposed untii they meet
"treatment standards."lt is your responsibility to ensure that
your waste is treated to these standards.
Remember to keep your waste determination records in
your files.
What is Acceptable Knowledge for Making
Hazardous Waste Determinations?
Acceptable knowledge may include:
•	Waste origin.
•	Composition.
•	Process knowledge (e.g., information about chemical
feedstocks and other inputs to the production
process).
•	Knowledge of products, by-products, and
intermediates produced by the manufacturing
process,
•	Chemical or physical characterization of wastes.
•	Information on the chemical and physical properties
of the chemicals used or produced by the process or
otherwise contained in the waste.
•	Testing that illustrates the properties of the waste.
•	Other reliable and relevant information about the
properties of the waste or its constituents.
www.epa.gov/hwgenerators

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Determining Your Generator Category
40 CFR 262.10(b) and 262.13
If you are not sure if you are an LQG, you should count the
amount of hazardous waste you generate per calendar
month. Be sure to count wastes that are:
•	Accumulated on site for anytime before disposal or
recycling.
•	Placed directly into an on-site treatment or disposal
unit.
•	Generated as still bottoms or sludges and removed
from product storage tanks.
Obtaining an EPA Identification Number
40 CFR 262.18
LQGs must have an EPA identification (EPA ID) number for
each site that generates hazardous waste.
To obtain an EPA ID number, you must complete and submit
EPA Form 8700-12, Notification of Regulated Waste Activity,
otherwise known as the Site ID Form. For information
on submitting this form in your state, locate your state
environmental agency's hazardous waste page or reach out
to your state contact found at this page: https://rcrainfo.
epa.gov/rcrainfoprod/action/public/public-site/state-
contacts. For the federal form and instructions, see www.
eDa.gov/hwaenerators/how-hazardous-waste-aenerators-
transporters-and-treatment-storaae-and-disposal.
Once you have submitted a form and it's approved, an EPA
ID number will be assigned to you for that specific location.
Managing Hazardous Waste On Site
40 CFR 262.17
An LQG may accumulate any quantity of hazardous waste
in containers, tanks, drip pads, and containment buildings
for up to 90 days without a RCRA permit, provided that you
meet the technical standards for the containment unit.
LQGs that meet all technical standards for hazardous waste
accumulation also may conduct non-thermal treatment
on waste in accumulation units without obtaining a
RCRA permit. Generators must clearly mark the date
that accumulation begins for each accumulation unit
storing hazardous waste so that it is visible for inspection.
Accumulation units must also be labeled with the words
"Hazardous Waste"and an indication of the nature of the
hazard (e.g., using the words ignitable, corrosive, toxic, or
reactive or another nationally recognized hazard label).
Examples of Nationally Recognized
Hazard Labels
Ignitable Liquid
Department of
Transportation (DOT) warning
label or placard
Toxic Substance
Occupational Safety and
Health Administration
pictogram
Reactive Liquid
National Fire Protection
Association hazard
identification system
LQGs are also responsible for complying with "emergency
preparedness and prevention"requirements.The LQG must
prepare a written contingency plan, make arrangements
with local emergency responders, and train employees on
hazardous waste management and emergency response.
If your facility accumulates wastes for more than 90 days, it
is considered a storage facility and must follow regulations
described in 40 CFR Parts 264/265 and 270, unless you
have been granted an extension by your EPA Regional
Administrator.
www.epa.gov/hwgenerators

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Preparing Hazardous Waste for Shipment
Off Site
40 CFR 262.30-262.33
You must package, label, and mark your waste containers,
and placard vehicles that carry the wastes according to the
DOT Hazardous Materials Transportation Act requirements
(49 CFR Parts 172, 173, 178, and 179). Commercial waste
handlers can advise you on the proper procedures, but you
remain responsible for compliance.
For further information, call the DOT Fiazardous Materials
information Line at 202 366-4488.
Containers also must be labeled with all applicable RCRA
waste codes prior to shipment. Alternative systems like
barcoding or radio frequency identification are acceptable
as well, as long as they can identify the wastes contained in
a specific container.
Using the Manifest
40 CFR 262.20-262.27
A Uniform Fiazardous Waste Manifest (EPA Form 8700-
22) must accompany all hazardous waste that is shipped
off site. A manifest is a multipart form designed to track
hazardous waste from the time it leaves the generation site
until it reaches the treatment, storage, and disposal facility
(TSDF) specified on the manifest. The manifest will help
you to track your waste during shipment and make sure it
arrives at the proper destination. The transporter and the
permitted facility that treats or disposes of your waste must
sign the manifest and send a copy back to you.
All generators now have the option of creating and
submitting their Uniform Fiazardous Waste Manifests
electronically using the e-Manifest system, a cheaper and
faster alternative to the paper form. The electronic manifest
system is now available in all states, territories, and Indian
Country. You can learn more about e-Manifest and register
to use it at www.epa.aov/e-manifest.

Reporting
40 CFR 262.41-262.43
Biennial Reporting
You are responsible for submitting a Biennial Report to your
state or EPA Regional Office. Reports submitted for wastes
generated and shipped off site must include your EPA ID
number and any other information about your hazardous
waste activities required by the form, such as a description
and quantity of waste and where it was sent. Some states
might require you to report annually.These reports give
EPA a better understanding of national hazardous waste
generation and disposal activities and amounts.
If you only export hazardous wastes, you are not required to
submit a Biennial Report. You do, however, have to submit
an annual report (40 CFR 262.83).
Exception Reporting
if you do not receive a signed manifest from the final
destination facility for your hazardous waste:
•	After 35 days, you must attempt to locate the
hazardous waste by contacting the permitted facility.
•	After 45 days if the manifest is not located, you
must submit to your state or EPA Regional Office an
Exception Report that contains a copy of the original
manifest and a cover letter describing your efforts to
locate the shipment and the results of your efforts.
www.epa.gov/hwgenerators

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Recordkeeping
40 CFR 262.40
Be sure to retain the following records at the facility for at
least three years: signed manifests; biennial and exception
reports; waste determination documentation such as test
results or generator knowledge; and waste analyses. The
3-year period is automatically extended during the course
of any unresolved enforcement actions.
Complying with Land Disposal Restrictions
40 CFR Part 268
Wastes must meet certain treatment standards prior to land
disposal. When you transport your waste to a treatment
facility, you must send a notice informing the facility that
the waste does not yet meet treatment standards. The
notice should contain enough information about the
waste and the applicable standards so the facility can make
sure the appropriate standards are met before disposal. A
certification is required in some situations. You can contact
your state agency or EPA Regional office for help with
notification and certification requirements. If you treat your
waste on site, you must maintain a waste analysis plan. See
EPA's website for more information: www.epa.gov/hw/land-
disposal-restrictions-hazardous-waste.
Export/Import Requirements
40 CFR Part 262 Subpart H
If you choose to export your hazardous waste, you must
notify EPA at least 60 days before the intended date of
shipment to request consent to export. Export is prohibited
until you receive an EPA "Acknowledgement of Consent"
letter documenting consent from 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 requirements,
please go to www.eDa.gov/hwaenerators/information-
exporters-resource-conservation-and-recoverv-act-rcra-
hazardous-waste.
Importers of hazardous waste must have EPA ID numbers
and are responsible for complying with all generator
requirements in 40 CFR Part 262 Subparts A-D and F,
except those related to actual accumulation on site (see 40
CFR 262.17), since hazardous waste import shipments are
already in transit when they enter the country. Importers
of hazardous waste must also comply with import-specific
generator requirements in 40 CFR Part 262 Subpart H.
Importers of hazardous waste must be U.S. citizens and
must certify that the shipment is in compliance with all
applicable rules under the Toxic Substances Control Act
(TSCA). For more information onTSCA, call EPA'sTSCA
Assistance Hotline at 202 554-1404. U.S. facilities receiving
imported hazardous waste for recycling or disposal must
comply with the import-specific RCRA hazardous waste
manifest and international movement document tracking
requirements in 40 CFR Part 262 Subpart H and 40 CFR Part
264/265. For more information on how to comply with
the hazardous waste import requirements, please go to
www.epa.gov/hwgenerators/information-importers-and-
receiving-facilities-resource-conservation-and-recoverv-
act#Summarvlmport.
July 2020
EPA 530-F-20-003
www.epa.gov/hwgenerators
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