What is a hazardous waste generator?

A hazardous waste generator is any person(s) who produce a hazardous waste that falls under definitions of Title 40 of the Code of Federal Regulations (CFR). The EPA breaks down generators into three generator statuses based upon the amount of hazardous waste they produce. The categories are:

  • Conditionally Exempt Small Quantity Generators
  • Small Quantity Generators
  • Large Quantity Generators

The amount of hazardous waste produced by a generator each month determines their generator status and prevailing regulatory requirements.

Conditionally Exempt Small Quantity Generators (CESQGs)

Conditionally Exempt Small Quantity Generators (CESQG) are limited to generating 100 kilograms or less per month of hazardous waste. They can also only generate one kilogram or less per month of acutely hazardous waste. Some of the CESQG’s requirements include:

  • Must identify all the hazardous waste generated.
  • May not accumulate more than 1,000 kilograms of hazardous waste at any time.
  • Must ensure that hazardous waste is delivered to a person or facility who is authorized to manage it.

Small Quantity Generators (SQGs)

Small Quantity Generators (SQGs) are allowed to generate more than 100 kilograms, but should not exceed 1,000 kilograms of hazardous waste per month. The main requirements for SQG’s are:

  • May accumulate hazardous waste on-site for 180 days without a permit.
  • The amount of hazardous waste on-site should never exceed 6,000 kilograms.
  • Must comply with hazardous waste manifest and pre-transport requirements (40 CFR part 262, subpart B and 40 CFR §§262.30 through 265.33).
  • Must manage hazardous waste in tanks or containers requirements (40 CFR §265.201, 40 CFR part 265 subpart I, and 265.178)
  • Must comply with preparedness and prevention requirements (40 CFR part 265 subpart C) and land disposal restriction requirements (40 CFR part 268).
  • Must always have at least one employee available to respond to an emergency.
    • They are the emergency coordinator responsible for coordinating all emergency response measures.
  • Unlike LQGs, SQGs are not required to have written contingency plans.

Large Quantity Generators (LQGs)

Large Quantity Generators (LQGs) produce 1,000 kilograms per month, or more, of hazardous waste. They can or do also generate more than one kilogram per month of acutely hazardous waste. The main requirements for LQGs are:

  • May accumulate waste on-site for only 90 days. Unless a certain exception is applied.
  • Do not have limits on the amount of hazardous waste accumulated on-site.
  • Hazardous waste generated must be managed in tanks, containers, drip pads or containment buildings requirements (40 CFR part 265, subparts J, I, W and DD)
  • Must comply with the hazardous waste manifest and pre-transport requirements (40 CFR part 262 subpart B and 40 CFR §§262.30 through 265.33)
  • LQGs must comply with the preparedness and prevention requirements (40 CFR part 265 subpart C), contingency plan/emergency procedures (40 CFR part 265 subpart D) and land disposal restriction requirements (40 CFR part 268)
  • Must submit biennial hazardous waste reports.