Looking for a simple rubric to assist you in determining your status as a generator of hazardous waste?
Just remember this number.
If you generate less than 220 pounds of D, U, F or K listed Hazardous Waste in a one month period and NO P-listed materials, then you are a Very Small Quantity (VSQG). If this is the case, the legal requirements you must adhere to are the easiest to comply with.
VSQG's do not have a time limit for storage of waste materials, do not need an EPA ID#, and do not need to keep manifest records. VSQG's must still identify and dispose of Hazardous waste in a State Permitted Hazardous Waste or solid waste disposal facility.
If you generate more than 220 but less than 2200 pounds of D, U, F or K listed Hazardous Waste and no more than 2.2 pounds of P-listed materials in a one month period, then you are a Small Quantity Generator (SQG). Remember, no more than 2.2 pounds or acutely hazardous waste can be generated and stored in both the SAA's and the MAA. Requirements for SQG's are more stringent than VSQG's but significantly less than for LQG's.
SQG's must identify and properly label Hazardous Waste, store it in the MAA for no more than 180 days, obtain an EPA ID#, utilize manifests for shipping hazardous waste and maintain records for at least three years.
If you generate greater than 2200 pounds of D, U, F or K listed Hazardous Waste and more than 2.2 pounds of P-listed materials in a one month period, then you are a Large Quantity Generator (LQG). If this is the case, you must comply with the most stringent code of conduct.
LQG's may store materials in the MAA for no more than 90 days, have an established employee training program, have a formalized written contingency plan for emergencies and spills, submit biennial reports to EPA as well as comply with SQG requirements above.
It is up to each generator to properly assess and track their status. Practicing waste minimization in the laboratory and including your EH + S team in the purchasing process, are both great ways to reduce the potential of accidentally knocking yourself up the 2.2 ladder.
*Please remember that this is a partial list of requirements and that each State Department of Environmental Protection has a greater than or equal to clause when it comes to complying with 40 CFR 261. Check with your local government for further regulatory information.