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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

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