Frequent Questions

Are conditionally exempt small quantity generators (CESQG) required to perform weekly inspections for hazardous waste containers according to the requirement in 40 CFR Section 265.174?

No, there is no federal requirement for CESQGs to perform inspections on hazardous waste containers. Large quantity generators (LQG) and small quantity generators (SQG) are required to perform weekly inspections in areas where containers are stored (Section 262.34(a)(1)(i) and Section 262.34(d)(2)). Specifically, generators should check for leaks and deterioration caused by corrosion or other factors. States, however, can be more stringent than the Federal regulations and may require inspections of containers from all generators.

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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