If your facility generates more than 2,200 pounds of hazardous waste in any calendar month or stores more than 13,200 pounds of hazardous waste on-site at any time.  Facilities generating and storing less than these limits are subject to either the Small Quantity Generator (SQG) or Very Small Quantity Generator (VSQG) regulations.

Hazardous waste regulations were established to minimize human and environmental exposure to hazardous substances.  The Environmental Protection Agency (EPA) has written a comprehensive set of regulations that govern the management of hazardous waste from the point of generation to disposal.  They also incorporate a record keeping/reporting/tracking system to verify and document that the waste is, in fact, managed appropriately.  Finally, compliance with hazardous waste regulations is an enforceable law.  Noncompliance can result in fines of up to $37,500 per day for each violation.

All waste generators must, at a minimum:

• Accurately characterize each facility waste as hazardous or non-hazardous.
• Maintain an inventory documenting the facility’s monthly hazardous waste generation rate and the amount of hazardous waste stored on-site.
• Manage hazardous wastes in compliance with applicable on- and off-site federal regulations. 

Regulatory Requirements

EPA Identification Number

LQGs must obtain an EPA Hazardous Waste Generator Identification Number.  This number is used to identify the facility and the hazardous waste activities occurring there.  It is also required on all waste shipping papers.  An ID number is obtained by completing the form enclosed in EPA Form 8700-12 - Notification of RCRA Subtitle C Activity.

Waste Generation, Accumulation, and Storage

• Hazardous waste storage containers must remain sealed except during the addition or removal of waste.
• Hazardous waste storage containers must be clearly labeled “Hazardous Waste”.
• Up to 55 gallons of hazardous waste may be accumulated at the point of generation and under the supervision of the individual generating the waste for an indefinite period of time.  The container must be labeled “Satellite Accumulation.”  When 55 gallons has accumulated, the satellite accumulation container must be moved to a permanent hazardous waste storage area within 3 days and relabeled “Hazardous Waste.”
• Hazardous waste containers must be marked with the date they first received waste or the date when moved from the satellite accumulation area to the permanent hazardous waste storage area.
• The permanent hazardous waste storage area must be inspected weekly for leaking containers and proper container labeling and dating. This is done to assure the containers are sealed and to maintain adequate access to all containers.  Weekly inspections should be documented in a logbook that is maintained on-site.
• Hazardous waste may not be stored on-site for more than 90 days.

Preparation for Off-Site Transportation

Hazardous waste storage containers must be packaged, labeled, and marked according to the Department of Transportation’s (DOT) hazardous materials transport regulations.

Shipping Papers

• All shipments of hazardous waste must be accompanied by a Uniform Hazardous Waste Manifest. The manifest is a multiple copy form that must be signed by the generator, transporter, and disposal facility personnel.  Each entity should keep its respective copy of the form.  The original copy of the manifest must be returned to the generator by the disposal facility within 45 days.
• Both the generator and original copy of the manifest must be filed on-site and be readily available for inspection for at least three years.
• For waste subject to Land Ban restrictions, a Land Disposal Restriction Notification (LDR) form must accompany the hazardous waste manifest.  The transporter/disposal facility will assist in determining if a LDR is required.  If so, a copy must remain on-site and be readily available for inspection for at least three years.

Preparedness and Prevention

Hazardous waste storage areas must be maintained and operated to minimize the possibility of fire, explosion, or release of hazardous waste. The areas must also be equipped with or provide immediate access to the following:

• Internal communications or alarm system;
• A telephone to summon emergency assistance from local authorities;
• Fire extinguisher and control equipment;
• Spill control equipment; and
• Water to supply hoses or sprinkler systems.

Contingency Requirements

A written Contingency Plan, containing the following items, must be kept on file at the facility:

Emergency procedures used in response to fires, explosions, or release of hazardous waste.

Description of arrangements made with local police, fire department, hospital, and emergency response teams for coordinating emergency service.Names, addresses, and phone numbers (office and home) of all designated emergency coordinators.

For full contingency requirements, download the PDF on the right.

Training

Facility personnel must complete training (classroom or on-the-job) that includes procedures for using, inspecting, repairing, and replacing facility emergency equipment; communication or alarm systems; response to fires or explosions; response to groundwater contamination; and shutdown of operations. This training must be completed within six months after employment and include an  annual review of training.

For full contingency requirements, download the PDF on the right.

Recordkeeping

• Generator and original copies of hazardous waste disposal manifests must be maintained for at lease three years.
• Land Disposal Restriction Notification forms must be maintained for five years.
• Laboratory data documenting hazardous/non-hazardous waste determinations must be kept for three years from the date that the waste was last sent to treatment, storage, or disposal.
• Documentation of hazardous waste storage area inspections, employee training, emergency agency notification, etc., must be maintained on-site and be readily available for inspection.