What’s Your Status?

Waste is just a normal part of doing business and while many companies usually generate municipal solid waste, occasionally they will need to dispose of chemical products that are considered hazardous. How an organization manages its hazardous waste can be a major determining factor in whether it succeeds or fails. Poor planning or lack of understanding of state and federal guidelines could lead to lost profits due to unforeseen disposal expenses or hefty fines. Even nonprofit entities such as churches and schools are subject to penalties if they mishandle the hazardous wastes they generate.

The first step in properly managing hazardous wastes is determining an organization’s generator status. The EPA has defined three classes for generators based on how much hazardous waste they generate in an average month at a particular site. The classes are large quantity generators, small quantity generators and conditionally exempt small quantity generators. If an organization’s site generates hazardous wastes other than universal wastes such as light bulbs and paint related material, they will fall under one of these classifications.

Large Quantity Generators (LQG) generally produce over 1000 kilograms (2200 pounds) of hazardous waste each month and Small Quantity Generators (SQG) produce less than 1000 but more than 100 kilograms each month. These wastes can include corrosive cleaning chemicals and flammable solvents that have been used or are otherwise no longer needed. Large quantity and small quantity generators have to apply for EPA ID numbers and must meet certain storage requirements and accumulation time limits. They are also required to have contingency plans and special employee training that helps to mitigate damage if there is a chemical spill or other emergency incident.

A site that generates less than 100 kilograms (roughly 220 pounds or roughly 25 gallons) in an average month is considered a conditionally exempt small quantity generator (CESQG). These generators don’t have the same reporting requirements as companies that produce more waste and they do not have an accumulation time limit. Although they are not required by law to have contingency plans and emergency procedures in place as a CESQG, they are still highly encouraged to have these plans in order to protect employees and property in the event of an emergency.

Sometimes a generator site that is classified as CESQG will have more than 100 kilograms of waste to dispose of at a time. If this happens due to an infrequent event such as a clean out of old chemical products, the generator would still be considered conditionally exempt but may need to fill out a one-time shipment request if they are located in the state of Texas. It’s normally a good idea to frequently take stock of the chemical products at a specific site and quickly dispose of the ones that are known to be wastes in order to stay compliant with regulations.

Many small quantity generators dispose of hazardous waste so infrequently that they may not be familiar with the regulations governing proper handling and disposal so Protect Environmental helps small businesses determine their generator status and dispose of their hazardous chemical wastes. Our certified personnel have been packing, profiling, manifesting and disposing of special and hazardous wastes since 1996 and are ready to provide a disposal solution for your organization.

Feel free to contact our office or follow the link to the EPA’s website to learn more.
http://www.epa.gov/osw/hazard/generation/summary.htm

HUBNFPA Member

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