Frequent Questions

Are conditionally exempt small quantity generators (CESQGs) required to obtain EPA identification (ID) numbers?

CESQGs do not need to obtain EPA ID numbers because they are exempt from the notification requirements in RCRA Section 3010 (40 CFR Section 261.5(b)). However, authorized states may have more stringent requirements for obtaining an ID number than the federal program.

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.

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