An Overview of Hazardous Waste Generator Regulations (Part 1)

Hazardous waste is a waste with properties that make it potentially dangerous or harmful to human health or the environment. Hazardous wastes can be solids, liquids or gases. The facility that generates hazardous waste must comply with federal program that manages hazardous waste from cradle to grave.

For the material to be deemed as a hazardous waste it must first qualify as a waste and then as hazardous. A facility environmental professional is considered to be most knowledgeable about the process and should determine which waste streams are hazardous.

Secondly, the waste stream must exhibits any of the following four hazardous characteristics:

1. Ignitability
2. Corrosivity
3. Reactivity
4. Toxicity

Obviously, there are documented procedures to confirm if the waste stream is indeed hazardous.  The facility is responsible for characterizing its waste as hazardous or non-hazardous. It must determine whether a hazardous waste exhibits one of the above characteristics, by either testing it or applying knowledge of the hazardous waste characteristics to their waste to see if they apply.

Based upon the quantity of the hazardous waste generated at the site, the generator can be one of the following three categories:

Conditionally Exempt Small Quantity Generator (CESQG)

CESQGs produce 220 pounds or less of hazardous waste per month. In addition, CESQG produce less than 2.2 pounds of acutely hazardous waste, or 220 pounds, or less, of contaminated stuff resulting from the cleanup of an acute hazardous waste spill.

Small Quantity Generator (SQG)

SQGs produce between 220 pounds and 2,200 pounds of hazardous waste per month. In addition, SQG produce less than 2.2 pounds of acutely hazardous waste per month.

Large Quantity Generators (LQG)

LQGs produce 2,200 pounds or more of hazardous waste per month, or more than 2.2 pounds of acutely hazardous waste.

Sometimes generators exceed their normal generation limits in any given month. Say a CESQG generates 3,000 pounds of hazardous waste during an outage at the facility. The CESQG becomes an LQG for that month and must meet all the LQG requirements for that month only. This fluctuation between generator categories is called Episodic Generation.

There are 37 specific requirements for hazardous waste generators and each facility’s obligation vary depending upon the generator category.  If you have any questions, or would like to assess the hazardous waste program at your facility, please contact Sam Joshi at (215) 389-2811.