Hazardous Waste Management

Determining Your Generator Status

Are You a LQG?

If you generate 1,000 kg (about 2,200 pounds) or more of hazardous waste or more than 1 kg of acutely hazardous waste in any calendar month, you are a large quantity generator (LQG). LQGs must comply with all of EPA’s hazardous waste management rules although a partial exemption from some rules is available to generators that store (accumulate) hazardous waste on-site for less than 90 days. The principal advantage to removing accumulated hazardous waste off-site within 90 days is that it exempts you from needing a hazardous waste storage permit and having to comply with the rules applicable to permitted TSDFs.

A SQG?

If you generate more than 100 kg and less than 1,000 kg of hazardous waste and no more than 1 kg of acutely hazardous waste in any calendar month, you are a small quantity generator (SQG). You are subject to all hazardous waste regulations, except that formal training programs for employees, biennial reports, and a written contingency plan are not required.

Like LQGs, an SQG may accumulate hazardous waste on-site without a storage facility permit provided that you comply with the accumulation time requirements specific to SQGs.

A CESQG?

If you generate no more than 100 kg (about 220 pounds) of hazardous waste and no more than 1 kg (about 2 pounds) of acutely hazardous waste in any calendar month, you are a conditionally exempt small quantity generator (CESQG). Federal hazardous waste laws require you to:

  • Identify all hazardous waste you generate.
  • Send this waste to a hazardous waste facility or a landfill, or other facility approved by the state for industrial or municipal wastes.
  • Never accumulate more than 1,000 kg of hazardous waste on your property. (If you do, you become subject to all the requirements applicable to generators of 100–1,000 kg in any calendar month.)
  • As a CESQG, you are not required to obtain an EPA ID number. However, authorized states may have more stringent requirements than the federal program.

Also, if you generate more than the quantities of hazardous and acutely hazardous waste that define this special generator classification, you will lose your CESQG status.