Although CESQGs are not subject to recordkeeping, including notification, biennial reporting, and manifest requirements, they are still subject to limited generator waste management standards. 40 CFR §261.5 sets forth the special requirements for hazardous waste generated by the conditionally exempt small quantity generators.
However, some states may require recordkeeping or collect data on CESQGs through inspections, you should contact your state environmental agency for guidance on CESQG recordkeeping requirements.
State Web sites are located at the following URL:
The regulations referenced above are available online at www.ecfr.gov.
Note: On November 28, 2016, EPA published the Hazardous Waste Generator Improvements Final Rule, which makes several revisions to the hazardous waste generator regulations including the designation of CESQG changing to very small quantity generator (VSQG). Other revisions may also affect the information provided in this FAQ. The final rule and additional information, including a fact sheet, frequent questions, and a webinar recording and slides, are available at www.epa.gov/hwgenerators/final-rule-hazardous-waste-generator-improvements.
The Hazardous Waste Generator Improvements Final Rule is effective on May 30, 2017; however, implementation in a particular state depends on the state’s authorization status. A discussion of the effect that this final rule will have on state authorization is available on page 85801 of the rule. Information about how the rule will affect the requirements in this FAQ in a particular state is best obtained from the state hazardous waste program. A list of state hazardous waste programs is available at www.epa.gov/hwgenerators/links-hazardous-waste-programs-and-us-state-environmental-agencies.