Hazardous waste is generated at nearly every federal facility. Common hazardous wastes include waste paint, waste solvents, waste adhesives, waste solder, spill cleanup waste.
The first step in identifying whether or not you have hazardous waste is determining whether or not what is being generated is a "solid waste." Guidance on making that determination and associated exemptions can be found at HERE. Once the waste is identified as being a "solid waste," the next step is determining whether or not it is a hazardous waste. The process for making that determination, along with guidance on wastes specifically excluded from being classed as hazardous waste can be found HERE.
Clarification as to whether or not specific wastes are hazardous wastes has been issued for: byproducts; batteries; mercury-containing items; miscellaneous items such as aerosol cans, antifreeze, paint wastes, pesticide rinse water, pharmaceutical wastes, and used refrigerants; and petroleum wastes. Click HERE to view EPA's guidance on these issues.
The October 2016 revisions to the hazardous waste regulations placed an additional emphasis on facilities knowing what generator category they fell under.
What is a Hazardous Waste?
A step by step guide to determining if your waste is or is not a hazardous waste.
Very Small Quantity Generator (VSQG)
A VSQG is defined as meeting the following:
Small Quantity Generator (SQG)
A SQG is defined as meeting the following:
- Facilities generate less than 1000 kg [2200 lb] of non-acute hazardous waste in one calendar month but greater than 100 kg [220 lbs] of non-acute hazardous waste in one calendar month.
- Onsite accumulation time does not exceed 180 days.
- Facilities generate less than or equal to 1 kg/mo [2.2 lb/mo] of acute hazardous waste is generated in one calendar month.
- Facilities generate less than or equal to 100 kilograms (220 lbs) of any residue or contaminated soil, water, or other debris resulting from the cleanup of a spill, into or on any land or water, of any acute hazardous waste in one calendar month.
- Total onsite accumulation does not exceed more than 6000 kg [approx. 13,227 lb].
If a facility exceeds any of the listed parameters, it must operate as a Large Quantity Generator.
Large Quantity Generator (LQG)
A LQG is defined as meeting the following:
With the October 2016 revision of the hazardous waste generator regulations EPA has acknowledged that, from time to time, events happen which cause a generator of hazardous waste to exceed their generation/storage thresholds.
A classification whereby waste batteries, waste excess pesticides, waste fluorescent tubes, and waste mercury-containing equipment do not have to be disposed of as hazardous waste.
A classification of certain waste streams whereby waste batteries, waste excess pesticides, waste fluorescent tubes, and waste mercury-containing equipment do not have to be disposed of as hazardous waste.