Generators: Small Quantity

Renotification Requirement

SQGs must renotify the EPA or their state agency of their generator status every four years, with the next report due September 1, 2025.

Episodic Generation Flexibility

SQGs can temporarily exceed normal waste limits without changing their generator category if they follow set management requirements.

Improved Emergency Preparedness

SQGs must maintain updated emergency contact information and ensure quick access to emergency response arrangements.

Labeling Enhancements

Containers must display “Hazardous Waste” and identify hazard types (e.g., ignitable, toxic).

Clarified Regulations

Existing requirements and rules have been reorganized and clarified for easier compliance and enforcement.

Small Quantity Generators must renotify the EPA by September 1, 2025, using Form 8700-12, also known as a Site ID Form (or the state equivalent). Electronic reporting via the MyRCRAID system is an option in some states.

• EPA Identification: An EPA Identification Number must be obtained.

• Waste Accumulation: SQGs may accumulate up to 6,000 kg of hazardous waste on site for 180 days (or 270 days if the waste is transported over 200 miles).

• Container Standards: Hazardous waste must be stored in compatible, clearly labeled containers, indicating both the accumulation start date and applicable hazard indicators.

• Manifest System: SQGs are required to use the EPA’s manifest system to track all shipments of hazardous waste to permitted Treatment, Storage, and Disposal Facilities (TSDFs).

• Employee Training: Personnel must receive comprehensive training in proper waste handling procedures and emergency response protocols.

• Emergency Preparedness: Facilities must maintain up-to-date contingency plans and emergency contact information.

• Waste Minimization: SQGs are required to make a good-faith effort to reduce both the volume and toxicity of hazardous waste generated.

• Renotification: SQGs must renotify the EPA or their state agency regarding generator status every four years.

• Waste Determination: Misclassification or lack of documentation for waste streams.

• Improper Labeling of Containers: Missing “Hazardous Waste” labels, hazard indicators, and/or accumulation start dates.

• Exceeding Accumulation Time or Quantity Limits: Keeping waste onsite beyond 180/270 days or exceeding the 6,000 kg limit.

• Employee Training: Staff not trained, or training not documented.

• Missing or Incomplete Manifests: Failure to use or retain hazardous waste shipping manifests properly.

• Lack of Emergency Preparedness Measures: No contingency plan, emergency contact info, or access to communication tools.

• Failure to Renotify EPA or State Agency: Not submitting Form 8700-12 every four years as required.

• Improper Storage Conditions: Containers left open and/or incompatible wastes stored together.