US hazardous waste · Checklist

VSQG, SQG or LQG? Hazardous Waste Generator Status Checklist

Your monthly quantity of hazardous waste sets your obligations. Get it wrong and storage limits, training and reporting follow you.

Independent guide published by Wastetide. Not affiliated with, endorsed by or operated by the U.S. EPA or its e-Manifest system. For official filings use EPA's official e-Manifest website.

Key takeaways

  • Status is determined monthly by the quantity of hazardous waste generated, not stored.
  • VSQG: 100 kg or less per month (and 1 kg or less of acute hazardous waste).
  • SQG: more than 100 kg and less than 1,000 kg per month.
  • LQG: 1,000 kg or more per month, or more than 1 kg of acute hazardous waste.
  • States can be stricter than the federal rules: always check your state program.

Federal categories at a glance

 
VSQG
SQG
LQG
Monthly generation
≤ 100 kg
> 100 kg and < 1,000 kg
≥ 1,000 kg
Acute hazardous waste
≤ 1 kg
≤ 1 kg
> 1 kg
On-site accumulation
≤ 1,000 kg at any time
Up to 180 days (270 if facility > 200 miles), ≤ 6,000 kg
Up to 90 days
EPA ID number
Not federally required
Required
Required
Manifest
Per state rules
Required
Required
Reporting
None federally
Re-notification every 4 years
Biennial report

How to count

  1. List every hazardous waste stream and its monthly quantity.
  2. Count waste when it is generated, not when shipped.
  3. Exclude wastes that are exempt or managed as universal waste.
  4. Keep monthly records to justify your category.
  5. Plan for episodic events (cleanouts, decommissioning) that can temporarily change your status.

Data centers and plants: typical triggers

  • Battery replacements managed outside universal waste rules.
  • Solvent and paint waste from maintenance.
  • Used oil and contaminated rags if not managed under used oil rules.
  • Laboratory chemicals.

Wastetide

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FAQ

Can a site change category from month to month?

Yes. Status is determined each calendar month, and episodic generation provisions cover certain planned or unplanned events.

Sources: EPA: Categories of hazardous waste generators

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