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Is Your Waste Generator Classification Correct?

Kevin Webber - Sep 14, 2018 11:27:46 AM

Hazardous-Waste-Sign-DrumsAs a hazardous waste generator, you are responsible for familiarizing yourself with state and federal regulations and determining your generator classification. Under the Resource Conservation and Recovery Act (RCRA) the Environmental Protection Agency (EPA) established three categories of generators in its hazardous waste generator regulations:

  • Very small quantity generators
  • Small quantity generators
  • Large quantity generators

The volume of hazardous waste that a generator produces in a calendar month determines which regulations apply to that generator. Let’s take a look at why it’s so important to make sure you know your proper classification and the regulations that apply to each category.

Why Your Waste Generator Status Must Be Correct

When it comes to compliance, you must stay on top of requirements for the different types of generators. The only way to do this correctly is to know the appropriate classification for your facility. Basically, the more waste your facility generates, the stricter the regulations. The consequences of non-compliance can range from failed inspections that result in fines and operations interruptions to risks to your employees and the environment.

For example, Macy’s, Inc. generated enough waste over several years to qualify as a small quantity generator, but failed to notify EPA and state authorities. As a result, the retailer was fined a civil penalty of $375,000. In another example, a waste disposal company mishandled medical waste at a South Carolina hospital. The company mislabeled nonhazardous waste as hazardous, which meant a greater amount of waste was erroneously processed as hazardous – changing the hospital’s generator status. When the hospital (unknowingly) didn’t meet the regulations and reporting requirements, they were fined. This underscores the importance of working with a knowledgeable, reliable waste services provider.

Regulations for Very Small Quantity Generators

Very small quantity generators (VSQGs) generate 100 kilograms (220 pounds) or less per month of hazardous waste or one kilogram ( 2.2 pounds) or less per month of acutely hazardous waste. This generator must:

  • Identify all hazardous waste that is generated
  • Deliver all hazardous waste to a person or facility authorized to manage it
  • Ensure that no more than 1,000 kilograms (2,200 pounds) of hazardous waste is accumulated at any time

See title 40 of the Code of Federal Regulations (CFR) for hazardous waste management standards. CFR §262.14 has a complete description of VSQG regulations.

Regulations for Small Quantity Generators

Small quantity generators (SQGs) generate more than 100 kilograms (220 pounds) and less than 1,000 kilograms 2,200 pounds) of hazardous waste per month. This generator must:

  • Never exceed 6,000 kilograms (13,200 pounds) of hazardous on-site waste
  • Comply with EPA’s hazardous waste manifest requirements and pre-transport requirements
  • Manage hazardous waste in tanks or containers subject to EPA requirements
  • Comply with EPA preparedness and prevention requirements
  • Comply with EPA land disposal restriction requirements
  • Always have at least one employee available to respond to an emergency and designated as the emergency coordinator responsible for coordinating all response measures

SQGs may accumulate hazardous waste on-site for 180 days without a permit or for 270 days if the waste is being shipped more than 200 miles. See 40 CFR part 262 for a complete description of the SQG regulations.

Regulations for Large Quantity Generators

Large quantity generators (LQGs) generate more than 1,000 kilograms (2,200 pounds) of hazardous waste or more than 1 kilogram (2.2 pounds) of acutely hazardous waste per month. This generator must:

  • Only accumulate waste on-site for 90 days (certain exceptions apply)
  • Manage hazardous waste in tanks, containers, drip pads or containment buildings subject to EPA requirements
  • Comply with EPA’s hazardous waste manifest requirements and pre-transport requirements
  • Comply with EPA preparedness, prevention, and emergency procedure requirements
  • Comply with EPA land disposal restriction requirements
  • Submit a biennial hazardous waste report

LQGs do not have a limit on the amount of hazardous waste accumulated on-site. See 40 CFR part 262 for a complete description of the LQG regulations.

What are Episodic Generators?

VSQGs or SQGs who exceed their usual calendar month quantity limits due to either a planned or unplanned event, may be able to maintain their existing category. EPA defines an “episodic event” as an activity or activities that do not normally occur during generator operations. A planned event is one that the generator has prepared for, such as short-term projects, tank cleanouts, or regular maintenance. Unplanned events include things such as accidental spills, production process upsets, or “acts of nature” such as floods, hurricanes or floods. There are specific conditions for a generator managing hazardous waste from an episodic event.

 

Most states are authorized to implement the RCRA program; however, the quantity limits for state generation categories can be different than the federal limits. EPA lists the states with different hazardous waste generator categories. By knowing your correct waste generator classification, your facility can maintain compliance by following proper state and federal regulations. Partner with a trusted, reliable waste services provider who can help you determine your generator status.

Topics: Hazardous Waste- Compliance

Kevin Webber

Kevin Webber

Articles written by Kevin Webber who is one of the partners at TriHaz Solutions.

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