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How States Size Up Hazardous Waste Generators

Posted on March 08, 2021 by Roseanne Bottone and Roger Marks

Except for Alaska and Iowa, which operate under Federal jurisdiction, each state runs an approved Resource Conservation and Recovery Act (RCRA) program for managing hazardous waste. Each state's program must be at least as stringent as the Federal RCRA regulations, but they are not required to be identical.

Differences between state hazardous waste programs range from small (but important) to significant. One area where variations are quite common is RCRA generator categories.

What is a Generator Category or Generator Status?

The federal regulations have three generator categories based on the quantity of hazardous waste a facility generates within a calendar month:

Large Quantity Generator (LQG)  

LQGs generate:
> 1,000 kg of non-acute hazardous waste
> 1 kg of acute hazardous waste
> 100 kg of acute hazardous waste mixed with debris
 
There are no accumulation limits for LQGs.

Small Quantity Generator (SQGs)  

SQGs generate:
>100 kg and < 1,000 kg of non-acute hazardous waste
< 1 kg of acute hazardous waste
< 100 kg of acute hazardous waste mixed with debris
 
SQGs can accumulate on site, at any one time:
< 6,000 kg of non-acute hazardous waste
< 1 kg of acute hazardous waste
< 100 kg of acute hazardous waste mixed with debris

Very Small Quantity Generator (VSQG)*

VSQGs generate:
< 100 kg of non-acute hazardous waste
< 1 kg of acute hazardous waste
< 100 kg of acute hazardous waste mixed with debris
 
VSQGs can accumulate on site, at any one time:
< 1,000 kg of non-acute hazardous waste
< 1 kg of acute hazardous waste
< 100 kg of acute hazardous waste mixed with debris

*Formerly known as Conditionally Exempt Small Quantity Generators or CESQGs. More on this later.

Why Your Generator Category Matters

Under RCRA, not all hazardous waste generators are treated equally. Large Quantity Generators (LQGs) are subject to the most stringent standards.

LQG facilities must:
  • Provide annual hazardous waste training for personnel;
  • Accumulate waste on site for no more than 90 days;
  • Comply with RCRA Air standards;
  • Store ignitable and reactive wastes at least 50 feet from the property line;
  • Submit biennial reports; and
  • Develop a comprehensive written contingency plan. 
SQGs and VSQGs are subject to fewer, and more lenient, hazardous waste management requirements.  

Below are just some of the unique generator categories enforced by individual states.  

Help meet annual EPA training and state training mandates for hazardous waste professionals at the next RCRA Hazardous Waste Management Refresher Webinar on March 16. 

Note on VSQG vs. CESQG

Often called the most significant hazardous waste rulemaking in decades, the RCRA Generator Improvements Rule (GIR) made major changes to the Federal hazardous waste management regulations. One of those changes was to re-name Conditionally Exempt Small Quantity Generators or CESQGs.

These generators are now referred to as Very Small Quantity Generators or VSQGs. As of March 1, 2021, thirty-three states had adopted the GIR. In states that have not yet adopted the GIR, VSQGs may still be referred to by their "old" name, Conditionally Exempt Small Quantity Generators or CESQGs.California hazardous waste generator categories

California

California never adopted US EPA’s conditional exemption for the smallest generator category, now called VSQG. So, in most cases, even generators that meet the VSQG criteria are not eligible for all the reliefs available under Federal regulations.

In California, most generators who meet the Federal VSQG criteria are regulated as Small Quantity Generators. (Learn more)

Kansas hazardous waste generator categoriesKansas

In Kansas, the threshold for a CESQG is lower than the Federal threshold. To be a CESQG in Kansas, you can generate up to 25 kg of hazardous waste per month only, instead of the 100 kg per month allowed under Federal regulations.

To round things out, Kansas adds an extra generator category. A “Kansas Small Quantity Generator” or KSQG can generate between 25 and 100 kg of hazardous waste per month. CESQGs and KSQGs in Kansas must abide by the same monthly limits for acute hazardous waste (< 1 kg) and acute hazardous waste spill residues (< 100 kg).Maryland hazardous waste generator categories

Maryland

Maryland only has two generator categories—Small and Large.

That said, the state regulations include an exclusion that allows LQGs to store waste on site for up to 180 days when certain conditions are met.

New Hampshire

Always an independent state, New Hampshire does not use the phrase “Large Quantity Generator” or the Federal criteria for generator size. Instead, a facility that generates more than 100 kilograms of hazardous New Hampshire hazardous waste generator categorieswaste in one month in the Live Free or Die State is called a “Full Quantity Generator” or FQG.

You’re also an FQG in New Hampshire if you use a drip pad, accumulate hazardous waste in a containment building, or meet the Federal LQG thresholds for acute hazardous waste or acute hazardous waste spill residues.  

Massachusetts

Massachusetts uses the same vocabulary as the Federal RCRA rules—LQG, SQG, and VSQG. But in the Bay State, the following wastes must be counted along with hazardous waste to determine a site’s generator category:Mass hazardous waste generator categories
  • Regulated recyclable material, and
  • Container inner liners containing residues of hazardous wastes.
Plus, Massachusetts generators must count hazardous waste and waste oil (or “used oil fuel”) separately. Sites that generate both are regulated as “dual generators” and are subject to unique counting thresholds for determining generator category (see 310 CMR 30.253(5)).

Minnesota

Minnesota hazardous waste generator categoriesMinnesota has an extra generator category called a Minimal Quantity Generator or MiniQG.

The quantity thresholds for MiniQGs require an annual count, instead of a monthly count like the others. Sites that generate less than 1 gallon or less than 100 lbs. of hazardous waste per year, and also generate no acute hazardous waste, are MiniQGs.

Washington

Washington State gives different names to the generator categories—Small (SQG), Medium (MQG), and Large (LQG).Washington dangerous waste generator categories

Not only that, but the state regulations don’t use the words “hazardous waste.” Instead, they call it “dangerous waste.” 

This is just a sample of the ways Federal and State hazardous waste regulations can differ. To manage your facility's hazardous waste compliantly, you must know your state regulations.

Included with RCRA Training: State Hazardous Waste Summaries 

When you choose Lion for your hazardous waste training, you get a Lion Membership that includes exclusive access to hazardous waste State Summaries.

Available for all 50 states and D.C., State Summaries lay out the key differences between each state program and the Federal RCRA regulations, from generator categories to Waste ID rules, waste codes, varying requirements universal waste, and where to find the state regulations you need to know.  

Current Lion Members: Find your State Summary in the Resources section at Lion.com/Members.. 

Learn your state's unique hazardous waste requirements with Lion's catalog of state hazardous waste online courses and live, instructor-led webinars: 

California Hazardous Waste Management
California Hazardous Waste Management Refresher 
New York Hazardous Waste Management
Texas Hazardous & Industrial Waste Management 
Washington Dangerous Waste Management
Massachusetts Hazardous Waste Management  

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Some of the limited quantity reliefs are identical across the intermodal transport rules, but others are reserved for specific modes of transport. Shippers can and should capitalize on these limited quantity reliefs when possible, but must recognize that some hazmat requirements still apply to shipping limited quantities.

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