General Description
CESQGs produce 100 kg or less of hazardous waste per month. CESQGs enjoy less burdensome RCRA record keeping and reporting requirements but must comply with the general hazardous waste management requirements. Pollution prevention techniques allow many hazardous waste generators to maintain CESQG status by minimizing waste or, in some circumstances, eliminate the hazardous waste stream entirely.
Summary of Federal Requirements
You are a CESQG if, and only if:
- you generate no more than 100 kg [approx. 220 lb] of hazardous waste in a calendar month
- total onsite accumulation does not exceed more than 1000 kg [approx. 2205 lb] of hazardous waste
- no more than 1 kg [approx. 2 lb] of acute hazardous waste is generated in a calendar month
- no more than a total of 100 kg [approx. 220 lb] of any residue or contaminated soil, waste, or other debris resulting from the cleanup of any acute wastes in a calendar month is generated.
If a facility exceeds any of the listed parameters, it must operate as a small quantity generator.
Common acute wastes (aka P-listed wastes) include acrolein, aldicarb, benzoic acid, calcium cyanide, cyanogens, Endrin, Endothall, fluorine, hydrogen cyanide, hydrogen phosphide, nitric oxide, parathion, phosgene, potassium cyanide, sodium azide, tetraethyl lead, toxaphene, warfarin, and zinc cyanide.
Facilities that were formerly small quantity generators have been able to scale back to being a CESQG by using the universal waste classification for its waste batteries, waste pesticides, or waste fluorescent tubes.
Hazardous waste from a CESQG must either be treated or disposed of in an onsite facility or delivered to an offsite TSDF. It cannot just be tossed in the trash!
Even though a CESQG is not legally required to use a manifest or obtain a. U.S. EPA hazardous waste identification number, many hazardous waste haulers will not transport hazardous waste from a facility without a manifest or identification number.
There are no specific hazardous waste storage requirements, it is best practice though to label containers "Hazardous Waste" and indicate a start date. NOTE: The start date is when the first waste is poured/placed into the waste container.
Summary of State Requirements
States may require CESQGs to obtain an ID number.
States may require CESQGs to use manifests.
States may not recognize the category of CESQG, instead they may require everyone to be managed as either a small or a large quantity generator.
States may recognize the category CESQG, but might call it something else, like a Very Small Quantity Generator.
State-by-state guidance concerning hazardous waste can be found at ENVCAP's Hazardous Waste Resource Locator.
Laws and Statutes
The Resources Conservation and Recovery Act, Subtitle C
