Understanding Your Generator Status

Posted on 1/29/2013 by Lion Staff

Any person who produces hazardous waste or causes hazardous waste to become subject to regulation is a generator of hazardous waste. Waste can be produced by industrial processes or through recycling and waste treatment. Wastes can become subject to regulation without actually being produced through the closure of a process or facility or the cleanup of an abandoned site or accidental release.
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 conditionally exempt small quantity generator.
Status Amount Per Month Applicable
Large Quantity Generator (LQG) 1,000 kg or more
(>1 kg acute hazardous waste)
40 CFR 262.34(a)
Small Quantity Generator (SQG) >100 kg or < = 1,000 kg 40 CFR 262.34(d)
Conditionally Exempt Small Quantity Generator (CESQG) 100 kg or less
(1 kg or less acute hazardous waste)
40 CFR 261.5

Knowing Your Generator Status
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
Large Quantity Generator (LQG) Yes Yes Yes
Small Quantity Generator (SQG) No No No
Conditionally Exempt Small Quantity Generator (CESQG) No No No

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

Changing Generator Status
Generator status is based on the amount of waste generated over the course of a month. If a facility generates 1,000 kg or more of hazardous waste in a month, then ALL of the waste generated that month must be managed as LQG waste. Any waste generated in previous months can be managed under the rules that applied in those months.
The original regulations don’t account for the possibility of status change, but many State and regional authorities have their own uncodified policies and procedures for handling temporary or permanent change in generator status.
Keeping Good Records
On March 1 of every even-numbered year, every facility that treats, stores, or disposes of hazardous waste and every large quantity generator must file a Biennial Report (EPA FORM 8700-13A) on their hazardous waste management activities for the previous year.
This means that if a facility generates a large quantity of hazardous waste (1,000 kg or more) during even a single month of 2013, then it must file a report in 2014 for all of the waste generated the previous year—not just for the waste generated in that month. The report must describe all the hazardous waste that was generated at the facility, how much was generated, and what happened to it. A best practice is to keep good records of your waste generation every month, even if you’re normally a small quantity generator.
Ensure you are always in compliance with accumulation rules with effective RCRA training. At Lion’s Hazardous/Toxic Waste Management Workshops, you’ll learn how to classify hazardous waste, determine your on-site storage options, count hazardous wastes, and more.
What do you find to be your biggest problem in determining generator status? Share comments below.

Tags: best, hazardous waste, practices, RCRA, reporting and recordkeeping

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