What’s Your Status? Waste Generator Status, That Is…

Posted by Selin Hoboy on Thu, Dec 04, 2014 @ 12:26 PM

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Any facility that generates hazardous waste must determine its generator status. Generator status is defined under the Environmental Protection Agency’s (EPA) Resource Conservation and Recovery Act (RCRA). 

Generator status is based on the quantity and type of waste generated, and it impacts the requirements with which a facility must comply. Essentially, the more waste generated, the stricter the regulations.


But before defining the types of generators, let’s also define “P-listed” waste, which is a special sub-category of hazardous waste that impacts generator status. P-listed waste is regulated not just as hazardous but as acutely hazardous, and examples of P-listed pharmaceutical wastes include: arsenic trioxide, nicotine, physostigmine and warfarin. 

  1. Large Quantity Generators (LQGs) are facilities that generate in a calendar month or accumulate at any time quantities of hazardous waste greater than 2,200 pounds or quantities of P-listed waste greater than 2.2 pounds. LQGs are subject to detailed requirements for training, contingency plans, and recordkeeping.
  2. Small Quantity Generators (SQGs) are facilities that generate between 220 and 2,200 pounds of hazardous waste per month. SQGs cannot accumulate more than 2.2 pounds of P-listed waste on-site at any given time.  For SQGs, a basic emergency plan and training are required. 
  1. Conditionally Exempt Small Quantity Generators (CESQGs) are facilities that generate less than 220 pounds of hazardous waste per month or less than 220 pounds of spill residue per month. CESQGs cannot accumulate more than 2.2 pounds of P-listed waste on-site at any given time. CESQG facilities cannot accumulate onsite more than 2200 pounds of non-acute hazardous waste at any one time prior to disposal. If this happens, the facility must then follow all the requirements of a small quantity generator.

CESQGs facilities may be exempt under RCRA from many of the requirements that apply to SQGs and LQGs. Depending on the state; they may also be exempt from obtaining an EPA ID number. The state of Tennessee is one such example where CESQGs do not have to get EPA ID numbers. 

Thirty four (34) state hazardous waste management regulations do not recognize or have some modification to the federal CESQG requirements. Many of these differences are relatively minor but some of the more stringent are listed below.

Seventeen (17) states (California, Colorado, Connecticut, Illinois, Kentucky, Louisiana, Maine, Massachusetts, Minnesota, New Hampshire, New Mexico, North Carolina, Ohio, Pennsylvania, Rhode Island, West Virginia, and Wisconsin) require CESQG generators to manage their hazardous waste in a permitted Subtitle C TSDF, thus prohibiting disposal in a municipal or industrial waste landfill or other municipal or industrial facility.

The District of Columbia and Kansas require generators between 50 and 100 kg/mo (110 and 220 lb/mo) and 25 and 100 kg/mo (55 and 220 lb/mo), respectively, to manage their waste in a permitted Subtitle C TSDF. Generators of less than 50 kg/mo (110 lb/mo) in the District of Columbia and 25 kg/mo (55 lb/mo) in Kansas may dispose of their waste in a municipal or industrial waste facility.

Federal regulations do not require CESQGs to submit annual or biannual reports, however, six states (Arizona, California, Louisiana, Minnesota, Rhode Island, and Washington), have reporting requirements for all generators of less than 100 kg/mo (220 lb/mo). California and Rhode Island require CESQGs to report every two years. Arizona, Louisiana, Minnesota, and Washington have annual reporting requirements. 

As always, check State regulations to ensure compliance with any deviations from the Federal Requirements. The Generator bears legal responsibility for proper compliance.

LQGs and SQGs are required to comply with 40CFR Part 262 as follows:

  • Identify and count waste.
  • Obtain an EPA ID number.
  • Comply with accumulation and storage requirements, which includes requirements for training and emergency arrangements.
  • Prepare the waste for transportation.
  • Track the shipment and receipt of such waste.
  • Meet recordkeeping and reporting requirements. 

Facilities falling into the CESQG category must identify their hazardous waste, comply with storage limit requirements, and ensue that the waste treatment or disposal whether on-site or offsite meets CESQG requirements. 

P-listed waste or hazardous pharmaceutical waste can be managed through Stericycle services for Hospitals/IDNs, as well as, drug disposal services right-sized for smaller entities, such as physician offices and assisted living facilities. Read the Pharmaceutical Waste Management White Paper.

Topics: Pharma Waste Disposal

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