Hazardous Waste

A hazardous waste generator category classifies facilities based on how much hazardous waste they produce each month. This category determines the facility’s regulatory requirements, including limits, training, planning, and reporting obligations.

Facilities are categorized as:

• Very Small Quantity Generator (VSQG): ≤ 220 lbs. (100 kg.) per month
• Small Quantity Generator (SQG): 220–2,200 lbs. (100–1,000 kg.) per month
• Large Quantity Generator (LQG): > 2,200 lbs. (1,000 kg.) per month

The assigned category affects requirements such as accumulation limits, training, contingency planning, and reporting.

Yes, Small Quantity Generators (SQGs) and Large Quantity Generators (LQGs) must obtain an EPA Identification Number before shipping hazardous waste off-site. Some states also require Very Small Quantity Generators (VSQGs) to obtain one.

To obtain an EPA ID number, facilities must submit EPA Form 8700-12. Because state requirements may vary, it is important to check with your state environmental agency to confirm

“Cradle-to-grave” management means the generator of hazardous waste is responsible for it from the moment it is created until its final disposal. This includes all stages such as transport, treatment, and disposal, regardless of whether the waste leaves the facility.

This responsibility covers:

• Creation of the waste
• Transportation off-site
• Treatment and handling
• Final disposal

Even after the waste leaves the site, the generator remains legally and financially responsible for ensuring it is properly managed throughout its entire lifecycle.

The “Mixture Rule” means that if a listed hazardous waste is mixed with non-hazardous waste, the entire mixture is still considered hazardous. For characteristic wastes, the mixture is only considered hazardous if it continues to exhibit that characteristic.

Specifically:

• Listed hazardous waste + non-hazardous waste: the entire mixture remains hazardous, regardless of concentration
• Characteristic waste + non-hazardous waste: the mixture is hazardous only if it still shows the hazardous characteristic (e.g., flammability)

This rule determines how mixed wastes are classified and managed under hazardous waste regulations.

Land Disposal Restrictions (LDRs) prohibit the disposal of hazardous waste in landfills unless the waste meets specific treatment standards. Before disposal, generators must ensure the waste has been properly treated and documented.

Generators are required to provide an LDR notification to the Treatment, Storage, and Disposal Facility (TSDF) that certifies the waste’s status. This notification confirms whether the waste meets the required treatment standards before it can be landfilled.

Universal waste is a category of hazardous waste that is regulated under a streamlined set of rules to simplify handling and encourage recycling. While it is still considered hazardous waste, it is subject to less complex requirements.

Under 40 CFR Part 273, universal waste includes common items that contain lower levels of hazardous materials, such as:

• Batteries
• Lamps
• Pesticides
• Mercury-containing equipment
• Aerosol cans

These streamlined regulations are designed to promote proper management and recycling of widely generated hazardous materials while reducing regulatory burden.