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HOW MUCH WASTE DOES MY COMPANY GENERATE – AND WHAT DOES THAT MEAN?

There are many stipulations and requirements for any company that generates hazardous waste. The three different categories, as established by the EPA, are Conditionally Exempt Small Quantity Generators (CESQGs), Small Quantity Generators (SQGs), and Large Quantity Generators (LQGs).

What comes to mind when you think of hazardous waste generators? You’re probably picturing evil corporations dumping enormous, disintegrating, cylindrical drums filled with oozing green goo thrown haphazardly (pun intended) into a dilapidated, ramshackle part of town while the CEO’s and board members dive into their personal vaults of gold and jewels, Scrooge McDuck style. As fun as it would be to imagine such an obviously nefarious company practice, the reality is a little less “black and white”, and a lot more “gray”. There are actually many regulatory committees and laws in place to monitor the production of hazardous waste as well as the disposal of such materials. In fact, hazardous waste generators are grouped into three different categories depending on how much material they produce in a given month. The three different categories, as established by the EPA, are Conditionally Exempt Small Quantity Generators (CESQGs), Small Quantity Generators (SQGs), and Large Quantity Generators (LQGs). Now take a sip of your coffee, because detailed descriptions of all three of these are down below. So let’s get started!

The first category is Conditionally Exempt Small Quantity Generators (CESQGs). This group generates 100 Kilograms or less per month of hazardous waste, or one Kilogram or less per month of acutely hazardous waste (epa.gov). To those who are unfamiliar with the differentiation between the two waste characterizations, hazardous waste is waste with properties that make it potentially dangerous or harmful to human health or the environment. Acutely hazardous waste, on the other hand, is specific to any kind of hazardous waste with a waste code beginning with the letter “P” or any state-only hazardous materials with a waste code beginning with the letters “P”, “ORP”, or any of the following “F” codes; F020, F021, F022, F023, F026, and F027. CESQGs must identify all hazardous material generated, may not accumulate more than 1,000 kilograms of hazardous waste at any time, and must ensure that hazardous material is delivered to a person or facility who is authorized to manage it (epa.gov).

The next category of hazardous waste generators is Small Quantity Generators (SQGs). This group generates more than 100 Kilograms, but less than 1,000 kilograms of hazardous material per month (epa.gov). I hope you refilled your coffee, because this next part gets a little convoluted. There are several major requirements for SQGs and they include the ability to accumulate hazardous material on-site for 180 days without a permit (or 270 days if shipping a distance greater than 200 miles), complying with the Hazardous Waste Manifest and pre-transport requirements at 40 CFR part 262, subpart B and 40 CFR262.30 through 265.33, managing hazardous waste in tanks or containers (subject to the requirements found at 40 CFR 265.201 and 40 CFR part 265 subpart I except for 40 CFR 265.176 and 265.178, respectively), complying with the preparedness and prevention requirements at 40 CFR part 256 subpart C, and the land disposal restriction requirements at 40 CFR part 268, and they must also keep the quantity of hazardous waste on-site below the 6,000 Kilogram point at all times (epa.gov). By the way, for those of you playing the home game, CFR is the Code of Federal Regulations that these companies must adhere to in regards to their hazardous waste production. Different than the CESQGs, SQGs have to have one employee available on site to respond to an emergency. As you may have guessed, this employee is responsible for coordinating all emergency response measure, though he or she is not required to have a detailed, written contingency plan (epa.gov).

We’re coming into the proverbial home-stretch now, and the last category for hazardous waste generators is Large Quantity Generators (LQGs). LQGs generate 1,000 Kilograms per month or more of hazardous waste or more than one Kilogram per month of acutely hazardous waste (epa.gov). As with the other two categories, there are several restrictions, but given how much waste those in the group produce, their restrictions are far more limiting. LQG’s are only allowed to accumulate waste on-site for 90 days (though certain exceptions apply), but they don’t have a limit as to the amount of hazardous material they can accumulate in those 90 days. The hazardous waste they generate must be managed in tanks, containers, drip pads, or containment building subject to the requirements found at 40 CFR part 265, subpart J, I, W, and DD, respectively. LQGs must comply with the hazardous waste manifest and pre-transport requirements at 40 CFR part 262 subpart B and 40 CFR 262.30 through 265.33, and also with the preparedness and prevention requirements at 40 CFR part 265 subpart C, the contingency plan and emergency procedures at 40 CFR par 265 subpart D, and the land disposal restriction requirements at 40 CFR part 268 (epa.gov). LQGs are also required to submit a biennial hazardous waste report.

As you can see, there are many stipulations and requirements for any company that generates hazardous material. In fact, the Resource Conservation and Recovery Act allows individual states to impose their own laws and regulations for waste management programs. However the states will only gain approval from the EPA if it is “substantially equivalent to, consistent with, and is no less stringent than the federal program” (enviro.blr.com). They may even impose stricter laws than the federal requirements, but the company must follow whichever is the more rigorous of the two. The most important aspect of these restrictions is the proper monitoring and cataloging of hazardous waste that is deemed detrimental to the environment and the living beings that are a part of it. So it may not be as cut and dry as the fable told at the top of the page, but dividing up the hazardous material generators into the aforementioned groups (CESQGs, SQGs, and LQGs) is a step in the right direction, and a push for a more sustainable and cleaner future.

Mike Watts, President, Pinnacle Environmental Services, Inc. http://www.pinnacleenv.com

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