Stuff happens. One day you’re a conditionally exempt small quantity generator (CESQG) of hazardous waste, and then the next day you realize you’re a small quantity generator (SQG) of hazardous waste. Only it’s not one day that’s the issue; it’s one month, as hazardous waste generator status is determined by the volumes of hazardous waste generated monthly.
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As you know, you must add up the weight of all the hazardous waste your facility generates in a month with the total weight determining your generator class. The federal rule at 40 CFR 261.5 is the RCRA regulation that helps you to determine whether you’re a CESQG, an SQG, or a large quantity generator (LQG) of hazardous waste. It specifies which wastes are counted and which are excluded from being counted.