Search

3 Reasons VSQGs Use a Hazardous Waste Manifest

Posted on 10/3/2022 by Roseanne Bottone

Under the Federal Resource Conservation and Recovery Act (RCRA) a Very Small Quantity Generator or VSQG is a generator who, in a calendar month, generates:

  • < 1 kg of acute hazardous waste;
  • < 100 kg of non-acute hazardous waste; and
  • < 100 kg of acute hazardous waste residues from a cleanup of acute hazardous waste

The RCRA regulations formerly referred to this category as “conditionally exempt small quantity generators” or CESQGs. (What’s My Generator Status?) 

VSQGs and the Hazardous Waste Manifest

Provided that the VSQG meets all the conditions for exemption listed in 40 CFR 262.14, the generator is not required to use a Uniform Hazardous Waste Manifest to ship hazardous waste offsite for treatment, recycling, or disposal.

A provision in EPA’s Generator Improvements Rule allows VSQGs to ship hazardous waste offsite to a large quantity generator (LQG) for consolidation if both generators are under the control of the same person/entity, when the VSQG meets certain conditions. These shipments do not require a manifest either.

There are, however, three reasons that a VSQG will use a manifest to ship hazardous waste. In two of the three scenarios below, the receiving facility must enter the data into EPA's electronic manifest system. 
 

1. Voluntary use. 

The VSQG may elect to use the manifest when it’s not required to facilitate their own internal tracking. It’s not uncommon for destination facilities to request this practice as well. When the Manifest is used voluntarily (i.e., it's not required by Federal or State law), it should not be submitted to the electronic Manifest (e-Manifest) system. 
 

2. It's required by State RCRA program.

Many states require hazardous waste shipments from a VSQG to be accompanied by the Manifest. Manifests required by a State must be entered into the e-Manifest system.


3. To ship waste managed under the rules for "episodic generation." 

In states that have adopted Federal relief for hazardous waste generated during episodic events like spills or lab clean-outs, the VSQG is required to use a Manifest to ship the episodic waste off-site. These manifests must be entered into the e-Manifest system as well. 

3 Reasons VSQGs Use a Hazardous Waste Manifest

By understanding when a Manifest is required to ship hazardous waste, Very Small Quantity Generators can avoid rejected or returned shipments and maintain compliance with the RCRA regulations.

Generators or receiving facilities who enter manifest data into EPA's electronic system should know that, when a manifest was required by Federal or State law, it must be entered into the e-manifest system.

Online Training: RCRA Compliance for VSQGs 

VSQGs are exempt from many of the most burdensome RCRA compliance requirements—but only when they meet all conditions for exemption laid out in the regulations.

The RCRA for Very Small Quantity Generators online course covers keys to compliance with the Federal hazardous waste regulations for VSQG facilities—from identifying hazardous waste and universal waste to proper storage, labeling, and more.

Tags: hazardous waste management, manifest, RCRA, very small quantity generator, VSQG

Find a Post

Compliance Archives

Lion - Quotes

Given the choice, I would do all coursework this way. In-person courses go very fast without the opportunity to pause or repeat anything.

Ellen Pelton

Chemical Laboratory Manager

Lion is my preferred trainer for hazmat and DOT.

Jim Jani

Environmental Coordinator

I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for.

Frank Sizemore

Director of Regulatory Affairs

The instructor was very knowledgeable and provided pertinent information above and beyond the questions that were asked.

Johnny Barton

Logistics Coordinator

The instructor did an excellent job presenting a very dry subject; keeping everyone interested and making it enjoyable.

Marc Bugg

Hazardous Waste Professional

The instructor was very engaging and helped less experienced people understand the concepts.

Steve Gall

Safety Leader

Lion's online training is more comprehensive, has better slides, and is a superior training experience than what I would get from other trainers.

Robert Brenner

District Environmental Manager

The course was very well structured and covered the material in a clear, concise manner.

Ian Martinez

Hazmat Shipping Professional

The instructor took a rather drab set of topics and brought them to life with realistic real-life examples.

Tom Berndt

HSE Coordinator

Excellent job. Made what is very dry material interesting. Thoroughly explained all topics in easy-to-understand terms.

David Hertvik

Vice President

Download Our Latest Whitepaper

What to do before, during, and after a RCRA hazardous waste inspection to defend your site from rising State and Federal penalties.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.