Determining RCRA Generator Status in 2024

Posted on 12/28/2023 by Nick Waldron

Any person who produces hazardous waste or causes hazardous waste to become subject to regulation is a generator of hazardous waste.

A “person” can be an individual, but more generally, the term applies to a facility or site. The amount of hazardous waste generated at a site during a calendar month determines its generator status.

While the term “generator status” doesn’t actually appear in the Resource Conservation and Recovery Act (RCRA) or its implementing regulations, it is used by the EPA and others to refer to the amount of hazardous waste generated at a facility and the particular regulations that apply to that facility and its waste.

There are three categories of generator status: large quantity generator, small quantity generator, and very small quantity generator.

Very Small Quantity Generator (VSQG) 100 kg or less
(1 kg or less acute hazardous waste)
Small Quantity Generator (SQG) >100 kg or < = 1,000 kg
Large Quantity Generator (LQG) 1,000 kg or more
(>1 kg acute hazardous waste)

Knowing your generator status is the most important thing you can do under RCRA, because the more waste you generate, the more rules you have to follow.

Status Written Training Plan/Records Written Contingency Plan Biennial Report
Very Small Quantity Generator (VSQG) No No No
Small Quantity Generator (SQG) No No No
Large Quantity Generator (LQG) Yes Yes Yes

Not every State-level implementing authority recognizes the SQG or VSQG provisions, and may not extend every relief to every facility. As always, check your state-level agency rules/policies before making major policy changes.

Keeping Records & Changing Generator Status

On March 1 of every even-numbered year, large quantity generators must submit a Biennial Report that includes details about hazardous waste management activities during the previous calendar year.

If a facility generates a large quantity of hazardous waste (1,000 kg or more) during even a single month of 2023, then it must file a report in 2024 for all of the waste generated the previous year. The report must describe all the hazardous waste that was generated at the facility, how much was generated, and what happened to it.

Best practice is to keep good records of your waste generation every month, even if you’re normally a small quantity generator or even a very small quantity generator.

Because RCRA lists separate generator status thresholds for hazardous waste, acutely hazardous waste, and spill clean-up materials from acutely hazardous waste, it’s not unusual for your generator status to change from month depending on exactly what you generate.

The volume of hazardous waste your site produces in a given month can vary for many reasons. You may have had an extra productive month, for example, or a change in operations may lead to increased production.

RCRA compliance can be a rocky road. Ensure you are always in compliance with accumulation rules with effective RCRA training. At Lion’s RCRA Hazardous Waste Management, you’ll learn how to classify hazardous waste, determine your on-site storage options, count hazardous wastes, and more.

Tags: biennial report, hazardous waste management, RCRA

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