Hazardous Waste Management

How Do I Know If I Am a CESQG?

Federal requirements require CESQGs to:

  • Identify all hazardous waste generated.
  • Accumulate no more than 1,000 kg of hazardous waste at any time.
  • Accumulate no more than 1 kg of acute hazardous waste and/or a total of 100 kg of any residue or contaminated soil, waste, or other debris resulting from the cleanup of a spill of acute hazardous wastes at any time
  • Ensure that hazardous waste is delivered to a person or facility authorized to manage it if the waste is not treated or disposed of at your on-site facility.

Documentation and Reporting for CESQGs

There are no specific federal requirements for keeping records of the amount of hazardous waste generated by a CESQG. However, it is highly recommended.

This documentation provides a basis for determining your generator status each calendar month and is proof to any regulatory agency that may question your monthly generation rates. Hazardous waste that is sent to a TSDF is generally listed on a Uniform Hazardous Waste Manifest or a state manifest. The manifest provides the proper documentation for monthly generation of hazardous waste.  Although CESQGs are exempt from the federal manifest requirements and from obtaining an EPA identification number, some states or TSDFs may require the use of a manifest and some states may require an EPA identification number.

If, at any time, the monthly generation for the facility exceeds the CESQG limitations, EPA must be notified of your change of generator status for the remainder of the year even if the total hazardous waste generated during the year is 1,200 kilograms or less.


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How to Manage Your CESQG Regulated Quantities in Multiple Sites, Multiple States

Managing multiple facilities in multiple states can be quite confusing when it comes to hazardous waste regulation. So how does a CESQG count regulated quantities of hazardous waste when they have many facilities in different states? By each facility? By the company as whole?

By Site, Of Course!

The CESQG regulated quantities would be by site, so this means each site would be a different generator and the quantities would be per each of the sites. This is based on the assumption that there is not more than one generator on a contiguous piece of property. RCRA definitions say, a generator is “any person, by site, whose act or process produces hazardous waste identified or listed in 40 CFR 261 or whose act first causes a hazardous waste to become subject to regulation.” Although the regulations do not explicitly define the term “site,” EPA tracks hazardous waste generation on a site specific basis or by “individual generation site.”


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To do this, EPA issues unique identification numbers to identify generators by site. Activities occurring under the control of an owner or operator on a single piece of property should be evaluated collectively for hazardous waste generation.

EPA gives this example: if Company A operates three laboratories on a single piece of property, all three laboratories may share one EPA ID number, and the waste from all three laboratories may be evaluated together. If, however, Company A operates three laboratories at three different locations that are not considered to be on contiguous property, each laboratory is viewed as a separate potential generator and is required to obtain an individual EPA ID number.

See tomorrow’s Advisor for 5 things you didn’t know about CESQGs.

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