Frequent Questions

If a conditionally exempt small quantity generator (CESQG) accumulates more than 1 kg of acutely hazardous waste, that generator is regulated as a large quantity generator (LQG). How much acute hazardous waste may a small quantity generator (SQG) accumula

A person who generates acute hazardous waste is regulated as either a CESQG or LQG.  There is no SQG generator status for generators of acute hazardous waste.

A person generating less than or equal to one kilogram of acute hazardous waste per calendar month is a CESQG (40 CFR 261.5(f); see also letter from Shapiro to Joseph, December 23, 1993, (RCRA Online #11803)).   If a CESQG generates more than one kilogram of acute hazardous waste in a calendar month, then all acute hazardous waste would be subject to full regulation as applicable to LQGs for that month (40 CFR 261.5(e); see also Monthly Call Center Report Question; January 2004 ((RCRA Online #14700)).

The guidance memoranda referenced above are available in the RCRA Online database at the following URL: https://yosemite.epa.gov/osw/rcra.nsf/how+to+use?OpenForm.

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.

Have more questions? Submit a request