Frequent Questions

A large quantity generator (LQG) accumulates hazardous waste in both tanks and containers. The generator labeled each container with the date upon which the accumulation period began in accordance with 40 CFR Section 262.34(a)(2). Must this LQG also mark

The LQG must also mark hazardous waste accumulation tanks with the date upon which the hazardous waste accumulation period begins. Although this requirement is not cited in Section 262.34(a)(2), EPA intended for both tanks and containers to be marked with accumulation start dates (51 FR 10146, 10160; March 24, 1986). This requirement ensures that LQGs accumulate hazardous waste in accordance with the 90-day accumulation time limit.

Note: On November 28, 2016, EPA published the Hazardous Waste Generator Improvements Final Rule, which makes several revisions to the hazardous waste generator regulations. These revisions may 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

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

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