A Guide for Small Businesses

United States 

Environmental Protection 

Agency

1EPA

Solid Waste and

Emergency Response

(5305W)

EPA530-K-01-005

December 2001

www.epa.gov/osw

Hazardous

Waste

Managing Your
ii

1 INTRODUCTION

2 DECIDING WHETHER HAZARDOUS WASTE REGULATIONS APPLY TO YOU

2 Defining Hazardous Waste

3 Identifying Your Waste

3 Finding Your Generator Category

7 OVERVIEW OF REQUIREMENTS FOR CONDITIONALLY EXEMPT SMALL QUANTITY GENERATORS

8 OBTAINING AN EPA IDENTIFICATION NUMBER

11 MANAGING HAZARDOUS WASTE ON SITE

11 Accumulating Your Waste

13 Treating Your Waste To Meet the Land Disposal Restrictions

13 Preventing Accidents

14 Responding to Emergencies

16 SHIPPING WASTE OFF SITE

16 Selecting a Treatment, Storage, and Disposal Facility

16 Labeling Waste Shipments

17 Preparing Hazardous Waste Manifests

17 Land Disposal Restrictions (LDR) Reporting Requirements

18 Export Notification

18 Closure

21 SUMMARY OF REQUIREMENTS FOR LARGE QUANTITY GENERATORS

22 WHERE TO GET MORE HELP

22 EPA and Other Federal Resource Centers

24 EPA Regional Offices

26 ACRONYMS AND DEFINITIONS

CONTENTS
Does your business generate

hazardous waste? Many small

businesses do. If you need help

understanding which federal hazardous waste management regulations apply to your business, this

handbook is for you. It has been

prepared by the U.S. Environmental Protection Agency (EPA) to help

small-business owners and operators understand how best to comply with federal hazardous waste

management regulations.

This handbook provides an

overview of the regulations to give

you a basic understanding of your

responsibilities. It should not be

used as a substitute for the actual

requirements. All of the federal

hazardous waste regulations are

located in Title 40 of the Code of

Federal Regulations (CFR), Parts

260 to 299 (www.epa.gov/

epacfr40).

EPA defines three categories of

hazardous waste generators based

upon the quantity of hazardous

waste they generate per month:

(1) Conditionally exempt small

quantity generators (CESQGs),

which generate less than 220

lbs (100 kg) per month.

(2) Small quantity generators

(SQGs), which generate

between 220 lbs (100 kg) and

2,200 lbs (1,000 kg) per

month.

(3) Large quantity generators

(LQGs), which generate more

than 2,200 lbs (1,000 kg) per

month.

Each category of generator must

comply with the hazardous waste

rules specific to that category. This

handbook is intended primarily for

businesses that generate a small

quantity of hazardous waste (SQGs

and CESQGs) to help them learn

about regulations that apply to

them.

This handbook explains only the

federal requirements for hazardous

waste management. Many states

have their own hazardous waste

regulations based on the federal

hazardous waste regulations. In

some of these states, the requirements are the same as the federal

standards and definitions. Other

states, however, have developed

more stringent requirements than

the federal program. If this is the

case in your state, you must comply with the state regulations. To

become familiar with your state’s

requirements, consult your state

hazardous waste agency. For the

address or phone number for your

state agency, contact the RCRA

Call Center at 800 424-9346 or

TDD 800 553-7672.

INTRODUCTION

You can look up unfamiliarwords, phrases, or

acronyms in the list of definitions found on page 26.

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If you have questions about any part of this

book, or the federal hazardous waste regulations, contact the RCRA Call Center at 

703 412-9810 or TDD 703 412-3323 in the

Washington, DC, area or at 800 424-9346 or

TDD 800 533-7672 from other locations, or

<www.epa.gov/epaoswer/hotline>.

The Call Center provides free technical assistance. Any information you share will not be

used for any other purpose.

FOR MORE INFORMATION

1
DECIDING WHETHER HAZARDOUS WASTE 

REGULATIONS APPLY TO YOU

Defining Hazardous Waste

Awaste is any solid, liquid, or contained gaseous material that is

discarded by being disposed of,

burned or incinerated, or recycled.

(There are some exceptions for recycled materials.) It can be the byproduct of a manufacturing process

or simply a commercial product that

you use in your business—such as

a cleaning fluid or battery acid—and

that is being disposed of. Even

materials that are recyclable or can

be reused in some way (such as

burning solvents for fuel) might be

considered waste.

Hazardous waste can be one of

two types:

 Listed waste. Your waste is

considered hazardous if it

appears on one of four lists

published in the Code of

Federal Regulations (40 CFR

Part 261). Currently, more

than 500 wastes are listed.

Wastes are listed as hazardous because they are

known to be harmful to human

health and the environment

when not managed properly.

Even when managed properly,

some listed wastes are so

dangerous that they are called

acutely hazardous wastes.

Examples of acutely hazardous wastes include wastes

generated from some pesticides and that can be fatal to

humans even in low doses. 

 Characteristic wastes. If your

waste does not appear on

one of the hazardous waste

lists, it still might be

considered hazardous if it

demonstrates one or more of

the following characteristics:

 It catches fire under certain

conditions. This is known as

an ignitable waste. Examples

are paints and certain

degreasers and solvents.

 It corrodes metals or has a

very high or low pH. This is

known as a corrosive waste.

Examples are rust removers,

acid or alkaline cleaning fluids, and battery acid.

 It is unstable and explodes

or produces toxic fumes,

gases, and vapors when

mixed with water or under

other conditions such as

heat or pressure. This is

known as a reactive waste.

Examples are certain

cyanides or sulfide-bearing

wastes.

 It is harmful or fatal when

ingested or absorbed, or it

leaches toxic chemicals into

the soil or ground water when

disposed of on land. This is

known as a toxic waste.

Examples are wastes that

contain high concentrations

of heavy metals, such as cadmium, lead, or mercury.

You can determine if your waste is

toxic by having it tested using the

Toxicity Characteristic Leaching

Federal hazardous waste

management regulations

apply to most businesses

that generate hazardous

waste. To determine if

these regulations apply to

your business, you must

first determine if you even

generate hazardous

waste.

Determine if you generate hazardous waste

in the first place.

Measure the amount of hazardous waste that

you produce per month.

Determine your generator category to learn the

management requirements that apply to you.

2
3

Procedure (TCLP), or by simply

knowing that your waste is hazardous or that your processes generate hazardous waste. For more

information about the TCLP and

other test methods, contact the

RCRA Call Center or the Methods

Information Communication

Exchange (MICE) at 703 676-4690

or <www.epa.gov/sw-846>.

Identifying Your Waste

To help you identify some of thewaste streams common to your

business, consult the table on

page 4 to find a list of typical hazardous wastes generated by small

businesses. Use the insert in the

middle of this handbook for a

more detailed listing of the EPA

waste codes associated with these

waste streams to determine if your

waste is hazardous. Commercial

chemical products that are discarded might also become hazardous

waste. For a complete listing of

hazardous waste codes, see 40

CFR Part 261.

If your waste is hazardous, you will

need to manage it according to

appropriate federal regulations.

Finding Your Generator

Category

Once you know that you generate hazardous waste, you

need to measure the amount of

waste you produce per month. The

amount of hazardous waste you

generate determines your generator category. 

Many hazardous wastes are liquids

and are measured in gallons—not

pounds. In order to measure your

liquid wastes, you will need to convert from gallons to pounds. To do

this, you must know the density of

the liquid. A rough guide is that 30

gallons (about half of a 55-gallon

drum) of waste with a density similar to water weighs about 220

pounds (100 kg); 300 gallons of a

waste with a density similar to

water weighs about 2,200 lbs

(1,000 kg).

EPA has established three generator categories, as follows, each of

which is regulated differently:

CESQGs:

Conditionally Exempt Small

Quantity Generators: You are considered a CESQG if you generate

less than 220 lbs (100 kg) per

month of hazardous waste. You

are exempt from hazardous waste

management regulations provided

that you comply with the basic

requirements described on page 6.

If you are a CESQG and you generate no more than 2.2 lbs (1 kg) of

acutely hazardous waste (or 220

lbs (100 kg) of acutely hazardous

waste spill residues) in a calendar

month, and never store more than

that amount for any period of time,

you may manage the acutely hazardous waste according to the

CESQG requirements. If you generate or store more than 2.2 lbs

(1kg) of acutely hazardous waste

on site, you must manage it

according to the LQG requirements

(see below).

SQGs:

Small Quantity Generators: You

are considered an SQG if you generate between 220 and 2,200 lbs

(100 and 1,000 kg) per month of

hazardous waste. SQGs must comply with EPA requirements for managing hazardous waste described

in this document.

LQGs:

Large Quantity Generators: You

are considered an LQG if you generate more than 2,200 lbs (1,000

kg) per month of hazardous waste.

LQGs must comply with more

extensive hazardous waste rules

than those summarized in this

handbook. See page 21 for an

overview.

One way to help determine if your waste exhibits any of thecharacteristics listed on page 2 is to check the Material

Safety Data Sheet (MSDS) that comes with all products containing

hazardous materials (www.msdsonline.com for information). In

addition, your national trade association or its local chapter might

be able to help you.

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4

TYPE OF BUSINESS

Drycleaning and 

Laundry Plants

Furniture/Wood

Manufacturing and

Refinishing

Construction

Laboratories

Vehicle

Maintenance

Printing and Allied

Industries

Equipment Repair

Pesticide EndUsers/Application

Services

Educational and

Vocational Shops

Photo Processing

Leather

Manufacturing

HOW GENERATED

Commercial drycleaning 

processes

Wood cleaning and wax removal,

refinishing/stripping, staining, painting, finishing, brush cleaning and

spray brush cleaning

Paint preparation and painting, carpentry and floor work, other specialty contracting activities, heavy

construction, wrecking and demolition, vehicle and equipment maintenance for construction activities

Diagnostic and other laboratory

testing

Degreasing, rust removal, paint

preparation, spray booth, spray

guns, brush cleaning, paint removal,

tank cleanout, installing lead-acid

batteries, oil and fluid replacement

Plate preparation, stencil preparation for screen printing, photoprocessing, printing, cleanup

Degreasing, equipment cleaning,

rust removal, paint preparation,

painting, paint removal, spray booth,

spray guns, and brush cleaning.

Pesticide application and cleanup

Automobile engine and body repair,

metalworking, graphic arts-plate

preparation, woodworking

Processing and developing negatives/prints, stabilization system

cleaning

Hair removal, bating, soaking,

tanning, buffing, and dyeing

TYPICAL WASTES

Still residues from solvent distillation, spent filter cartridges, cooked

powder residue, spent solvents,

unused perchloroethylene

Ignitable wastes, toxic wastes,

solvent wastes, paint wastes

Ignitable wastes, toxic wastes,

solvent wastes, paint wastes, used

oil, acids/bases

Spent solvents, unused reagents,

reaction products, testing samples,

contaminated materials

Acids/bases, solvents, ignitable

wastes, toxic wastes, paint wastes,

batteries, used oil, unused cleaning

chemicals

Acids/bases, heavy metal wastes,

solvents, toxic wastes, ink, unused

chemicals

Acids/bases, toxic wastes,

ignitable wastes, paint wastes,

solvents

Used/unused pesticides, solvent

wastes, ignitable wastes, contaminated soil (from spills), contaminated rinsewater, empty containers

Ignitable wastes, solvent wastes,

acids/bases, paint wastes

Acid regenerants, cleaners,

ignitable wastes, silver

Acids/bases, ignitables wastes,

toxic wastes, solvent wastes,

unused chemicals

TYPICAL HAZARDOUS WASTE GENERATED BY SMALL BUSINESSES

WASTE CODES

D001, D039, F002, F005, U210

D001, F001-F005

D001, D002, F001-F005

D001, D002, D003, F001-F005, U211

D001, D002, D006, D007, D008,

D035, F001-F005, U002, U080, U134,

U154, U159, U161, U220, U228,

U239

D002, D006, D008, D011, D019,

D035, D039, D040, D043, F001-F005,

U002, U019, U043, U055, U056,

U069, U080, U112, U122, U154,

U159, U161, U210, U211, U220,

U223, U226, U228, U239, U259,

U359

D001, D002, D006, D008, F001-F005

D001, F001-F005, U129, U136, P094,

P123

D001, D002, F001-F005

D001, D002, D007, D011

D001, D002, D003, D007, D035,

F001-F005, U159, U228, U220
WHAT IS YOUR GENERATOR CATEGORY?

Depending on your type of business, you might be regulated

under different rules at different times. If, for example, you generate less than 220 lbs (100 kg) of hazardous waste during the

month of June, you would be considered a CESQG for June, and

your June waste would be subject to the hazardous waste management requirements for CESQGs. If, in July, you generate

between 220 and 2,200 lbs (100 kg to 1,000 kg) of hazardous

waste, your generator status would change, and you would be

considered an SQG for July. Your July waste would then be subject

to the management requirements for SQGs. If you mix the wastes

generated during June and July, the entire mixture would be subject

to the more stringent SQG standards.

5

I

n many cases, small businesses that fall

into different generator categories at

different times choose to satisfy the more

stringent requirements to simplify

compliance.

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UNIVERSAL WASTES

The Universal Waste Rule was written to streamline environmental regulations for wastes generated by large

numbers of businesses in relatively small quantities. It is

designed to reduce the amount of hazardous waste disposed of in municipal solid waste, encourage the recycling

and proper disposal of certain common hazardous wastes,

and reduce the regulatory burden for businesses that generate these wastes.

Universal wastes are items commonly thrown into the

trash by households and small businesses. Although handlers of universal wastes can meet less stringent standards for storing, transporting, and collecting these

wastes, handlers must still comply with the full hazardous

waste requirements for final recycling, treatment, or disposal. By providing a waste management structure that

removes these wastes from municipal landfills and incinerators, this rule ensures stronger safeguards for public

health and the environment.

Universal wastes include:

 Batteries, such as nickel-cadmium (Ni-Cd) and small

sealed lead-acid batteries, which are found in many

common items, including electronic equipment, cell

phones, portable computers, and emergency backup

lighting.

 Agricultural pesticides that have been recalled or

banned from use, are obsolete, have become damaged, or are no longer needed due to changes in

cropping patterns or other factors. They often are

stored for long periods of time in sheds or barns.

 Thermostats, which can contain as much as 3 grams

of liquid mercury and are located in almost any building, including commercial, industrial, agricultural, community, and household buildings.

 Lamps, which typically contain mercury and sometimes lead, and are found in businesses and households. Examples include fluorescent, high-intensity

discharge (HID), neon, mercury vapor, high-pressure

sodium, and metal halide lamps.

Materials are continually added to the Universal Waste list;

check <www.epa.gov/epaoswer/hazwaste/id/univwast.htm>

for the latest information.

The Universal Waste Rule also encourages communities

and businesses to establish collection programs or participate in manufacturer take-back programs required by a

number of states. Many large manufacturers and trade

associations are already planning national and regional collection programs for their universal waste products.

For more information, see 40 CFR Part 273.
6

DO Measure:

All quantities of listed and characteristic hazardous wastes that

are:

 Accumulated on the property

for any period of time before

disposal or recycling.

(Drycleaners, for example,

must count any residue

removed from machines,

as well as spent cartridge

filters.)

 Packaged and transported

away from your business.

 Placed directly in a regulated

treatment or disposal unit at

your place of business.

 Generated as still bottoms

or sludges and removed

from product storage tanks.

DO NOT Measure:

Wastes that:

 Are specifically exempted

from counting. Examples

include lead-acid batteries

that will be reclaimed, scrap

metal that will be recycled,

used oil managed under the

used oil provisions of 40

CFR 279, and universal

wastes (e.g., batteries, pesticides, thermostats, and

lamps) managed under 40

CFR 273.

 Might be left in the bottom

of containers that have been

thoroughly emptied through

conventional means such as

pouring or pumping.

 Are left as residue in the bottom of tanks storing products, if the residue is not

removed from the product

tank.

 Are reclaimed continuously

on site without storing prior

to reclamation, such as

drycleaning solvents.

 Are managed in an “elementary neutralization unit,” a

“totally enclosed treatment

unit,” or a “wastewater treatment unit,” without being

stored first. (See Definitions

for an explanation of these

types of units.)

 Are discharged directly to

publicly owned treatment

works (POTWs) without being

stored or accumulated first.

This discharge to a POTW

must comply with the Clean

Water Act. POTWs are public

utilities, usually owned by

the city, county, or state, that

treat industrial and domestic

sewage for disposal.

 Have already been counted

once during the calendar

month, and are treated on

site or reclaimed in some

manner, and used again.

 Are regulated under the universal waste rule or have

other special requirements.

The federal regulations contain special, limited requirements for managing certain

commonly generated wastes.

These wastes can be managed following the less burdensome requirements listed

below instead of the usual

hazardous waste requirements. Check with your state

agency to determine if your

state has similar regulations.

Used oil—40 CFR Part 279

Lead-acid batteries that are

reclaimed—40 CFR Part

266, Subpart G

Scrap metal that is recycled—40 CFR 261.6 (a)(3)

Universal wastes (e.g., certain batteries, recalled and

collected pesticides, and

mercury-containing thermostats and lamps)—40 CFR

Part 273

WHAT DO YOU MEASURE TO DETERMINE YOUR GENERATOR CATEGORY?
First, you must identify all hazardous waste that you generate. Second, you may not store

more than 2,200 lbs (1,000 kg) of

hazardous waste on site at any

time. Finally, you must ensure

delivery of your hazardous waste

to an off-site treatment or disposal

facility that is one of the following,

or, if you treat or dispose of your

hazardous waste on

site, your facility

also most be:

 A state or federally regulated

hazardous

waste management treatment, storage,

or disposal

facility.

 A facility permitted, licensed,

or registered by a state to

manage municipal or industrial solid waste.

 A facility that uses, reuses, or

legitimately recycles the

waste (or treats the waste

prior to use, reuse, or

recycling).

 A universal waste handler or

destination facility subject to

the universal waste requirements of 40 CFR Part 273.

(Universal wastes are wastes

such as certain batteries,

recalled and collected pesticides, or mercury-containing

thermostats or lamps.)

Suggestion:

It’s a good idea to call the appropriate state agency to verify that

the treatment, storage, and disposal facility (TSDF) you have selected

has any necessary permits, etc.

You also may want to see that the

facility fits into one of the above

categories. (It’s a good idea to

document such calls for your

records.)

7

OVERVIEW OF REQUIREMENTS FOR CONDITIONALLY

EXEMPT SMALL QUANTITY GENERATORS

If you generate no more

than 220 lbs (100 kg) of 

hazardous waste per

month, you are a

Conditionally Exempt

Small Quantity Generator

(CESQG). You must comply

with three basic waste

management requirements

to remain exempt from the

full hazardous waste regulations that apply to generators of larger quantities

(SQGs and LQGs). 

(Note: there are different

quantity limits for acutely

hazardous waste.)

Identify your hazardous waste.

Comply with storage quantity limits.

Ensure proper treatment and disposal of your

waste.

STATE REQUIREMENTS

Some states have additional requirementsfor CESQGs. For example, some states

require CESQGs to follow some of the SQG

requirements such as obtaining an EPA identification number, or complying with storage standards. See page 14 for SQG storage

requirements.

CESQG
To obtain an EPA identification

number, you should:

 Call or write your state hazardous waste management

agency or the hazardous waste

division of your EPA Regional

office and ask for a copy of

EPA Form 8700-12,

“Notification of Hazardous

Waste Activity” (EPA Regional

offices are listed on pages 24

or visit <www.epa.gov/

epaoswer/hazwaste/data/form

8700/forms.htm>). You will be

sent a booklet that contains a

form with instructions and

those portions of the regulations that will help you identify

your waste. A sample copy of a

completed notification form is

shown on pages 9-10. (Note: A

few states use a form that is

different from the one shown.

Your state agency will send 

you the appropriate form to

complete.)

 Fill in the form as shown in the

example. To complete Item IX

of the form, you will need to

identify your hazardous waste

by its EPA Hazardous Waste

Code. A list of common hazardous wastes and their waste

codes can be found on the

insert in this handbook; for a

complete list of waste codes,

you should consult 40 CFR Part

261, or contact your state or

regional EPA office or the RCRA

Call Center. The form you

receive from your state might

contain an additional sheet

that provides more space for

waste codes. Complete one

copy of the form for each business site where you generate

or handle hazardous waste.

Each site will receive its own

EPA identification number.

Make sure you sign the certification in Item X.

 Send the completed form to

your state hazardous waste

contact. This address is listed

in the information booklet that

you will receive with the form.

EPA records the information on the

form and assigns an EPA identification number to the site identified on

your form. The EPA number stays

with the property when ownership

changes. If you move your business,

you must notify EPA or the state of

your new location and submit a new

form. If another business previously

handled hazardous waste at this

location and obtained an EPA

Identification Number, you will be

assigned the same number after

you have notified EPA that you have

moved to this location. Otherwise,

EPA will assign you a new identification number.

OBTAINING AN EPA IDENTIFICATION NUMBER

If your business generates

between 220 lbs (100 kg)

and 2,200 lbs (1,000 kg)

of hazardous waste per

month, you are an SQG,

and you must obtain and

use an EPA identification

number. EPA and states

use these 12-character

numbers to monitor and

track hazardous waste

activities. You will need to

use your identification

number when you send

waste off site to be 

managed.

Call your state agency to determine if you

need an EPA identification number.

If you do, obtain a copy of EPA Form 8700-12.

Fill in the form completely.

Send the form to your STATE hazardous waste

contact. 8

SQG
9

SAMPLE “NOTIFICATION OF REGULATED WASTE ACTIVITY” FORM

SQG
10

SAMPLE “NOTIFICATION OF REGULATED WASTE ACTIVITY” FORM (CONTINUED)

SQG
Accumulating Your Waste

Accumulating hazardous wasteon site can pose a threat to

human health and the environment,

so you may keep it only for a short

time without a permit. Before shipping the waste for disposal or recycling, you are responsible for its

safe management, which includes

safe storage, safe treatment, preventing accidents, and responding

to emergencies in accordance with

federal regulations.

SQGs can accumulate no more

than 13,228 lbs (6,000 kg) of hazardous waste on site for up to 180

days without a permit. You can

accumulate this amount of waste

for up to 270 days if you must

transport it more than 200 miles

away for recovery, treatment, or

disposal. Limited extensions may

be granted by the state director or

the regional EPA administrator. If

you exceed these limits, you are

considered a TSDF and must

obtain an operating permit. Wastes

generated in small amounts

throughout your facility may be

stored in satellite accumulation

areas located at or near the point

of generation of the waste. The

total amount of waste that may be

accumulated at a satellite area is

limited to 55 gallons. Once this

quantity has been exceeded, you

have 3 days to transfer the waste

to your designated 180-day (or

270-day) storage area.

(Note: Different quantity limits apply

to acutely hazardous wastes.)

SQGs must accumulate waste in

tanks or containers, such as 55-

gallon drums. Your storage tanks

and containers must be managed

according to EPA requirements

summarized below:

For containers, you must:

 Label each container with the

words “HAZARDOUS WASTE”

and the date that the waste

was generated.

 Use a container made of, or

lined with, a material that is

compatible with the hazardous waste to be stored.

(This will prevent the waste

from reacting with or corroding

the container.)

 Keep all containers holding

hazardous waste closed during storage, except when

adding or removing waste. Do

not open, handle, or store

(e.g., stack) containers in a

way that might rupture them,

cause them to leak, or otherwise fail.

 Inspect areas where containers are stored at least weekly.

Look for leaks and for deterioration caused by corrosion or

other factors.

 Maintain the containers in

good condition. If a container

leaks, put the hazardous waste

in another container, or contain

it in some other way that complies with EPA regulations.

 Do not mix incompatible

wastes or materials unless

precautions are taken to

prevent certain hazards.

11

MANAGING HAZARDOUS WASTE ON SITE

Accumulate wastes according to limits established by EPA for SQGs.

Follow the storage and handling procedures

required by EPA for SQGs.

Follow EPA requirements for equipment testing

and maintenance, access to communications or

alarms, aisle space, and emergency arrangements

with local authorities.

Most small businesses

accumulate some hazardous waste on site for a

short period of time and

then ship it off site to a

treatment, storage, or disposal facility (TSDF).

I

t is a good practice never to mix wastes. Mixing

wastes can create an unsafe work environment and

lead to complex and expensive cleanups and disposal.

TIP

SQG
12

 Do not mix wastes. Do not

mix nonhazardous waste with

hazardous waste. Once you

mix anything with listed hazardous waste, the whole

batch becomes hazardous.

Mixing waste can also make

recycling very difficult, if not

impossible. A typical example

of mixing wastes would be

putting nonhazardous cleaning agents in a container of

used hazardous solvents.

 Change materials, processes, or both. Businesses can

save money and increase

efficiency by replacing a

material or a process with

another that produces less

waste. For example, you

could use plastic blast

media for paint stripping of

metal parts rather than conventional solvent stripping.

 Recycle and reuse manufacturing materials. Many companies routinely put useful

components back into productive use rather than disposing of them. Items such

as oil, solvents, acids, and

metals are commonly recycled and used again. In addition, some companies have

taken waste minimization

actions such as using fewer

solvents to do the same job,

using solvents that are less

toxic, or switching to a detergent solution.

 Safely store hazardous products and containers. You

can avoid creating more hazardous waste by preventing

spills or leaks. Store hazardous product and waste

containers in secure areas,

and inspect them frequently

for leaks. When leaks or

spills occur, materials used

to clean them also become

hazardous waste.

 Make a good faith effort.

SQGs do not have to document their waste minimization activities or create a

waste minimization plan. You

do, however, need to certify

on your manifests that you

have made a good faith

effort to minimize waste generation when you send your

waste off site.

WASTE MINIMIZATION: THE KEY TO BETTER WASTE MANAGEMENT

The easiest and most cost-effective way of managing any waste is not to generate it in the first place. Youcan decrease the amount of hazardous waste your business produces by developing a few “good housekeeping” habits. Good housekeeping procedures generally save businesses money, and they prevent accidents and waste. To help reduce the amount of waste you generate, try the following practices at your

business.

SQG
13

For tanks, you must:

 Label each tank with the

words “HAZARDOUS WASTE”

and the date that the waste

was generated.

 Store only waste that will not

cause the tank or the inner

liner of the tank to rupture,

leak, corrode, or fail.

 Equip tanks that have an

automatic waste feed with a

waste feed cutoff system, or a

bypass system for use in the

event of a leak or overflow.

 Inspect discharge control and

monitoring equipment and the

level of waste in uncovered

tanks at least once each

operating day. Inspect the

tanks and surrounding areas

for leaks or other problems

(such as corrosion) at least

weekly.

 Use the National Fire

Protection Association’s

(NFPA’s) buffer zone requirements for covered tanks containing ignitable or reactive

wastes. These requirements

specify distances considered

to be safe buffer zones for

various ignitable or reactive

wastes. You can reach the

NFPA at 617 770-3000.

 Do not mix incompatible

wastes or materials unless

precautions are taken to prevent certain hazards.

 Do not place ignitable or reactive wastes in tanks unless

certain precautions are taken.

 Provide at least 2 feet (60

centimeters) of freeboard

(space at the top of each

tank) in uncovered tanks,

unless the tank is equipped

with a containment structure,

a drainage control system, or

a standby tank with adequate

capacity.

Treating Your Waste 

to Meet the Land Disposal

Restrictions (LDRs)

Most hazardous wastes maynot be land disposed unless

they meet “treatment standards.”

The Land Disposal Restrictions

(LDR) program requires that the

waste is treated to reduce the hazardous constituents to levels set

by EPA, or that the waste is treated using a specific technology. It is

your responsibility to ensure that

your waste is treated to meet LDR

treatment standards before it is

land disposed. (See page 17 for a

description of required LDR

notices.) Most SQGs probably will

have their designated TSDF do this

treatment. If you choose to treat

your waste yourself to meet LDR

treatment standards, there are

additional requirements including

waste analysis plans, notifications,

and certifications. To learn about

these requirements, contact the

RCRA Call Center, your state

agency, or EPA regional office, and

consult 40 CFR Part 268.

Preventing Accidents

Whenever you store hazardouswaste on site, you must minimize the potential risks from fires,

explosions, or other accidents. 

SQG
14

All SQGs that store hazardous

waste on site must be equipped

with:

 An internal communications or

alarm system capable of providing immediate emergency

instruction (voice or signal) to

all personnel.

 A device, such as a telephone

(immediately available at the

scene of operations) or a

hand-held, two-way radio,

capable of summoning emergency assistance from local

police and fire departments or

emergency response teams. 

 Portable fire extinguishers,

fire-control devices (including

special extinguishing equipment, such as those using

foam, inert gas, or dry chemicals), spill-control materials,

and decontamination

supplies.

 Water at adequate volume

and pressure to supply waterhose streams, foam-producing

equipment, automatic sprinklers, or water spray systems.

You must test and maintain all

equipment to ensure proper operation. Allow sufficient aisle space to

permit the unobstructed movement

of personnel, fire protection equipment, spill-control equipment, and

decontamination equipment to any

area of facility operation. Attempt

to secure arrangements with fire

departments, police, emergency

response teams, equipment suppliers, and local hospitals, as appropriate, to provide services in the

event of an emergency. Ensure

that personnel handling hazardous

waste have immediate access to

an alarm or emergency communications device.

You are not required to have a formal personnel training program, but

you must ensure that employees

handling hazardous waste are familiar with proper handling and emergency procedures. In addition, you

must have an emergency coordinator on the premises or on-call at all

times, and have basic facility safety

information readily accessible.

Responding to Emergencies

Although EPA does not requireSQGs to have a written contingency plan, you must be prepared

for an emergency at your facility.

You should also be prepared to

answer a set of “what if” questions. For example: “What if there

is a fire in the area where hazardous waste is stored?” or “What

if I spill hazardous waste, or one of

my hazardous waste containers

leaks?” In case of a fire, explosion, or toxic release, having such

a plan provides an organized and

coordinated course of action.

SQGs are required to establish

basic safety guidelines and

response procedures to follow in

the event of an emergency.

Worksheets 1 and 2 (on page 15)

can help you set up these procedures. The information on

Worksheet 1 must be posted near

your phone. You must ensure that

employees are familiar with these

procedures.

IF YOU THINK YOU HAVE AN EMERGENCY,

IMMEDIATELY CALL 911 AND THE NATIONAL

RESPONSE CENTER AT 800 424-8802.

I

n the event of a fire, explosion,

or other release of hazardous

waste that could threaten

human health outside the facility, or if you think that a spill has

reached surface water, call the

National Response Center to

report the emergency. The

Response Center will evaluate

the situation and help you make

appropriate emergency decisions. In many cases, you will

find that the problem you faced

was not a true emergency, but it

is better to call if you are not

sure. Serious penalties exist for

failing to report emergencies.

SQG
15

Worksheet 1 Fill in and post this information next to your telephone.

Worksheet 2 Fill in and post this information next to your telephone. Make sure all employees read and are familiar

with its contents.

✂

In the event of a spill:

Contain the flow of hazardous waste

to the extent possible, and as soon

as is possible, clean up the hazardous waste and any contaminated

materials or soil.

In the event of a fire:

Call the fire department and, if safe,

attempt to extinguish the fire using

a fire extinguisher.

In the event of a fire, explosion, or

other release that could threaten

human health outside the facility, or

if you know that the spill has

reached surface water:

Call the National Response Center

at its 24-hour number (800 424-

8802). Provide the following information:

Emergency Coordinator

Name: ________________________________________

________________________________________________

Telephone: ____________________________________

________________________________________________

________________________________________________

Fire Extinguisher

Location(s): ____________________________________

________________________________________________

________________________________________________

________________________________________________

Spill-Control Materials

Location(s): ____________________________________

________________________________________________

________________________________________________

Fire Alarm (if present)

Location(s): ____________________________________

________________________________________________

________________________________________________

________________________________________________

Fire Department

Telephone: ____________________________________

EMERGENCY RESPONSE INFORMATION

EMERGENCY RESPONSE PROCEDURES

Our company name:

__________________________________________________________________

__________________________________________________________________

Our address:

__________________________________________________________________

__________________________________________________________________

Our U.S. EPA identification number:

__________________________________________________________________

Date of accident __________________________________________________

Time of accident __________________________________________________

Type of accident (e.g., spill or fire) __________________________________

Quantity of hazardous waste involved ________________________________

Extent of injuries, if any ____________________________________________

Estimated quantity and disposition of recovered materials, if any

__________________________________________________________________ ✂

SQG
Package, label, and mark your shipment, and

placard the vehicle in which your waste is

shipped as specified in DOT regulations.

Prepare a hazardous waste manifest to accompany your shipment.

Include a notice and certification with the first

waste shipment.

Ensure the proper management of any hazardous

waste you ship (even when it is no longer in your

possession).

16

SQG

Selecting a Treatment,

Storage, and Disposal

Facility (TSDF)

SQGs may send their waste onlyto a regulated Treatment,

Storage, and Disposal Facility

(TSDF) or recycler. Most regulated

TSDFs and recyclers will have a

permit from the state or EPA.

Some, however, may operate under

other regulations that do not

require a permit. Check with the

appropriate state authorities to be

sure the facility you select has any

necessary permits. All TSDFs and

recyclers must have EPA identification numbers.

Labeling Waste Shipments

SQGs must properly package,label, and mark all hazardous

waste shipments, and placard the

vehicles in which these wastes are

shipped following Department of

Transportation (DOT) regulations.

Most small businesses use a commercial transporter to ship hazardous waste. These transporters

can advise you on specific requirements for placarding, labeling,

marking, and packaging; however,

you remain responsible for compliance. For additional information,

consult the DOT regulations (49

CFR Parts 172 and 173) or call

the DOT hazardous materials information line at 202 366-4488 or

800 467-4922.

Federal regulations allow you to

transport your own hazardous

waste to a designated TSDF provided that you comply with DOT rules.

Some states, however, do not

allow this practice. Call DOT and

your state hazardous waste management agency regarding applicable regulations.

SHIPPING WASTE OFF SITE

When shipping waste off

site, SQGs must follow

certain procedures that

are designed to ensure

safe transport and proper

management of the waste.
17

SQG

Preparing Hazardous Waste

Manifests

The Hazardous Waste ManifestSystem is a set of forms,

reports, and procedures designed

to seamlessly track hazardous

waste from the time it leaves the

generator until it reaches the offsite waste management facility

that will store, treat, or dispose of

the hazardous waste. The system

allows the waste generator to

verify that its waste has been properly delivered and that no waste

has been lost or unaccounted for

in the process.

The key component of this system

is the Uniform Hazardous Waste

Manifest, which is a multipart form

prepared by most generators that

transport hazardous waste for offsite treatment, recycling, storage,

or disposal. The manifest is

required by both the DOT and EPA.

When completed, it contains information on the type and quantity of

the waste being transported,

instructions for handling the

waste, and signatures of all parties involved in the off-site treatments, recycling, storage, or

disposal process. Each party also

must retain a copy of the manifest. This process ensures critical

accountability in the transportation

and disposal process. Once the

waste reaches its destination, the

receiving facility returns a signed

copy of the manifest to the generator, confirming that the waste has

been received.

At press time, the Uniform

Hazardous Waste Manifest system

is in the process of being updated

and modernized. Please check the

Internet at www.epa.gov/

epaoswer/hazwaste/gener/

manifest/index.htm. 

EPA expects to standardize the

content and appearance of the current manifest form so that the

same form may be used by waste

handlers nationwide. Other anticipated changes include improved

tracking procedures and an option

to complete, send, and store the

mainfest information electronically.

Land Disposal Restrictions

(LDR) Reporting

Requirements

Regardless of where the waste

is being sent, the initial shipment of waste subject to LDRs

must be sent to a receiving TSDF

or recycler along with an LDR

notice. You must send an additional LDR notice if your waste or

receiving facility changes. This

notice must provide information

about your waste, such as the EPA

hazardous waste code and the

LDR treatment standard. The purpose of this notice is to let the

TSDF know that the waste must
18

SQG

meet treatment standards before it

is land disposed. There is no

required form for this notice, but

your TSDF may provide a form for

you to use. A certification may

also be required in specific situations. Contact the RCRA Call

Center, your state agency, or EPA

regional office and consult 40 CFR

Part 268 for help with LDR notification and certification requirements.

Export Notification

I

f you choose to export your hazardous waste, you must notify

EPA 60 days before the intended

date of shipment to obtain written

consent. EPA’s “Acknowledge-ment

of Consent” document must

accompany the shipment at all

times. For more information on

how to obtain the consent to

export hazardous waste, contact

the RCRA Call Center at 800 424-

9346.

Closure

When you close your facility,you must ensure that all hazardous waste has been removed

from your hazardous waste tanks,

discharge-control equipment, and

discharge confinement structures.

In addition, any contamination you

might have caused must be

cleaned up and managed under all

applicable hazardous waste

regulations.
19

I

t is important to choose your transporter and your

TSDF carefully because you remain responsible for

the proper management of your hazardous waste

even after it has left your site.

For help in choosing a transporter or TSDF, check

with the following sources:

 References from business colleagues who have

used a specific hazardous waste transporter or

TSDF.

 Trade associations for your industry that might

keep a file on companies that handle hazardous

waste.

 The Better Business Bureau or Chamber of

Commerce in the TSDF’s area, which might have

a record of any complaints registered against a

transporter or a facility.

 Your state hazardous waste management

agency or EPA regional office, which can tell you

whether the transporter or TSDF has an EPA

identification number and a permit, if required.

Facility information, including types and quantities of waste managed and violations

assessed, can be accessed via the Envirofacts

Internet site at <www.epa.gov/enviro>.

SELECTING A TRANSPORTER OR TSDF/RECYCLER

SQG

EPA’s used oil management standards are a set of “good housekeeping” requirements that

encourage used oil handlers to

recycle used oil instead of disposing of it. Used oil can be collected,

refined and recycled, and used

again—for the same job or a completely different task.

Used oil is defined as “any oil that

has been refined from crude oil or

any synthetic oil that has been

used and, as a result of such use,

is contaminated by physical or

chemical impurities.” To meet

EPA’s definition of used oil, a substance must meet each of the following criteria:

 Origin. Used oil must have

been refined from crude oil or

made from synthetic materials. Animal and vegetable oils

are excluded from EPA’s definition of used oil.

 Use. Oils used as lubricants,

hydraulic fluids, head transfer

fluids, buoyants, and for other

similar purposes are considered used oil. Unused oil

such as bottom clean-out

waste from virgin fuel oil storage tanks or virgin fuel oil

recovered from a spill do not

meet EPA’s definition of used

oil because these oils have

never been used. EPA’s definition also excludes products

used as cleaning agents or

solely for their solvent properties, as well as certain petroleum-derived products such

as antifreeze and kerosene.

 Contaminants. To meet EPA’s

definition, used oil must

become contaminated as a

result of being used. This

includes residues and contaminants generated from handling,

storing, and processing used

oil. Physical contaminants can

include dirt, metal scrapings, or

sawdust. Chemical contaminants could include solvents,

halogens, or saltwater.

The following types of businesses

handle used oil:

 Generators are businesses

that handle used oil through

commercial or industrial operations or from the maintenance of vehicles and

equipment. Examples include

car repair shops, service stations, government motor

pools, grocery stores, metalworking industries, and boat

marinas. Farmers who produce less than an average of

25 gallons of used oil per

month are excluded from generator status. Individuals who

generate used oil through the

maintenance of their personal

vehicles and equipment are

MANAGING USED OIL
20

SQG

not subject to regulation

under the used oil management standards.

 Collection centers and aggregation points are facilities

that accept small amounts of

used oil and store it until

enough is collected to ship it

elsewhere for recycling.

 Transporters are companies

that pick up used oil from all

sources and deliver it to rerefiners, processors, or burners.

Transfer facilities are any structure or area where used oil is

held for longer than 24 hours

but not longer than 35 days.

 Re-refiners and processors

are facilities that blend or

remove impurities from used

oil so the oil can be burned

for energy recovery or reused.

 Burners burn used oil for

energy recovery in boilers,

industrial furnaces, or in hazardous waste incinerators.

 Marketers are handlers that

either a) direct shipments of

used oil to be burned as fuel in

regulated devices or b) claim

that certain EPA specifications

are met for used oil to be

burned for energy recovery in

devices that are not regulated.

Although different used oil handlers have specific requirements,

the following requirements are

common to all types of handlers:

Storage

 Label all containers and tanks

as Used Oil.

 Keep containers and tanks in

good condition. Do not allow

tanks to rust, leak, or deteriorate. Fix structural defects

immediately.

 Never store used oil in anything other than tanks and

storage containers. Used oil

also can be stored in units

that are permitted to store

regulated hazardous waste.

Oil Leaks or Spills

 Take steps to prevent leaks

and spills. Keep machinery,

equipment, containers, and

tanks in good working condition, and be careful when transferring used oil. Keep sorbent

materials available at the site.

 If a leak or spill occurs, stop

the oil from flowing at the

source. If a leak can’t be

stopped, put the oil in another

holding container or tank.

 Contain spilled oil using sorbent berms or spreading sorbent over the oil and

surrounding area.

 Clean up the used oil and

recycle it as you would have

before it was spilled. If recycling is not possible, you

must first make sure the used

oil is not a hazardous waste

and dispose of it appropriately. All used cleanup materials,

including rags and sorbent

booms, that contain used oil

must also be handled according to the used oil management standards.

 Remove, repair, or replace the

defective tank or container

immediately.

Used oil requirements are detailed

in 40 CFR Part 279. For more

information, contact the Emergency

Response Division’s Information

Hotline at 202 260-2342.
21

SUMMARY OF REQUIREMENTS FOR LARGE QUANTITY

GENERATORS

If you are a Large Quantity Generator (LQG) (generating more than 2,200 lbs (1,000

kg) per month), you must comply with the full set of hazardous waste regulations. This

table summarizes the federal LQG requirements. This is only a summary and does not

include all of the LQG requirements. For more details, contact the RCRA Call Center at

800 424-9346, or TDD 800 553-7672, or see 40 CFR Part 262. Be sure to check with

your state as well because certain states have additional or more stringent requirements than the federal government.

LQG Requirements

Hazardous Waste Determination

(40 CFR Part 262.10)

Generator Category Determination

(40 CFR Part 262.10 (b) and 261.5 (b)

and (c))

EPA Identification Numbers

(40 CFR 262.12)

Prepare Hazardous Waste for Shipment

Off Site (40 CFR Parts 262.30 - 262.33)

The Manifest

(40 CFR Parts 262.20 - 262.23, 262.42)

Managing Hazardous Waste On Site

(40 CFR Part 262.34)

Recordkeeping and Biennial Report

(40 CFR Parts 262.40 - 262.41)

Comply with Land Disposal Restrictions

(40 CFR 268)

Export/Import Requirements

(40 CFR Subparts E and F)

Air Emissions (40 CFR Part 265,

Subpart CC)

Closure (40 CFR Parts 265.111 and

265.114)

Summary

Identify all hazardous wastes you generate. Measure the amount of hazardous waste you

generate per month to determine your generator category (e.g., LQG).

Obtain a copy of EPA Form 8700-12, fill out the form, and send it to the contact listed with

the form. An EPA identification number will be returned to you for your location.

Package, label, mark, and placard wastes following Department of Transportation requirements. Ship waste using hazardous waste transporter.

Ship waste to hazardous waste treatment, storage, disposal, or recycling facility. Ship hazardous waste off site using the manifest system (EPA Form 8700-22) or state equivalent.

Accumulate waste for no more than 90 days without a permit. Accumulate waste in containers, tanks, drip pads, or containment buildings. Comply with specified technical standards for

each unit type.

Retain specified records for 3 years. Submit biennial report by March 1 of even numbered

years covering generator activities for the previous year.

Ensure that wastes meet treatment standards prior to land disposal. Send notifications and

certifications to TSDF as required. Maintain waste analysis plan if treating on site.

Follow requirements for exports and imports, including notification of intent to export and

acknowledgement of consent from receiving country.

If applicable, use various monitoring and control mechanisms to:

• Control volatile organic compound (VOC) emissions from hazardous waste management

activities.

• Reduce organic emissions from process vents associated with certain recycling activities

and equipment that is in contact with hazardous waste that has significant organic content.

• Control VOCs from hazardous waste tanks, surface impoundments, and containers using

fixed roofs, floating roofs, or closed-vent systems routed to control devices.

Decontaminate and remove all contaminated equipment, structures, and soil, and minimize

the need for further maintenance of your site. Meet unit-specific closure standards for tanks,

containment buildings, and drip pads.

LQG
22

WHERE TO GET MORE HELP

For further assistance in

understanding the hazardous waste regulations

applicable to you, contact

your state hazardous waste

agency. Other assistance

resources include the EPA

Resource Centers (including the RCRA Call Center),

or your EPA regional office

(page 24).

Also, see other related sections of

the Code of Federal Regulations:

 Handling PCBs (40 CFR Part

761)

 Toxic Release Inventory (TRI)

Reporting (40 CFR Part 372)

 Domestic Sewage Waste

Disposal Reporting (40 CFR

Part 403)

 Shipping Hazardous Materials

(49 CFR Parts 171-180)

EPA and Other Federal

Resource Centers

RCRA Call Center

U.S. Environmental Protection

Agency

1200 Pennsylvania Ave, NW.

Washington, DC 20460

Phone: 800 424-9346, or TDD

800 553-7672. In Washington,

DC: 703 412-9810, or 

TDD 703 412-3323

Web: www.epa.gov/epaoswer/hotline

Answers questions on matters

related to solid waste, hazardous

waste, and underground storage

tanks. Also can be used to find

and order EPA publications.

RCRA in Focus

RCRA in Focus is a series ofshort informational booklets

that describes the RCRA regulations as they apply to specific

industry sectors. The documents

explain what RCRA is, who is

regulated, and what hazardous

waste is; provide a sample life

cycle of a RCRA waste in each

industry; include a quick reference chart of all applicable

RCRA regulations and a series

of waste minimization suggestions for various specific industrial processes; and provide

information on other relevant

environmental laws and a page

of contacts and resources. 

Individual issues of RCRA in

Focus have been written for the

following industries:

• Dry Cleaning (EPA530-K-99-

005)

• Leather Manufacturing

(EPA530-K-00-002)

• Motor Freight & Railroad

Transportation (EPA530-K00-003)

• Photo Processing (EPA530-

K-99-002)

• Printing (EPA530-K-97-007)

• Vehicle Maintenance

(EPA530-K-99-004)

Other issues of RCRA in Focus

will cover:

• Wood Preserving/Wood

Products

• Construction, Demolition &

Renovation

• Metals Manufacturing

• Furniture Manufacturing

• Pharmaceutical

Manufacturing

• Laboratories

Copies of RCRA in Focus can be

obtained by contacting the RCRA

Call Center at 800 424-9346 or

TDD 800 553-7672 and requesting the document numbers listed above. You can also view the

documents online at

<www.epa.gov/

epaoswer/hazwaste/id/infocus/

index.htm>.
23

Small Business Ombudsman

Clearinghouse/Hotline

U.S. Environmental Protection

Agency

Small Business Ombudsman

(1230C)

1200 Pennsylvania Ave, NW.

Washington, DC 20460

Phone: 800 368-5888 or 

202 260-1211

Fax: 202 401-2302

Web: www.epa.gov/sbo

Helps private citizens, small businesses, and smaller communities

with questions on all program

aspects within EPA.

Department of Transportation

(DOT) Hotline

Office of Hazardous Materials

Standards (DOT)

Research and Special Programs

Administration

400 7th Street, SW.

Washington, DC 20590-0001

Phone: 202 366-4488 or 

800 467-4922

Fax: 202 366-3753

Web: http://hazmat.dot.gov

Answers questions on matters

related to DOT’s hazardous materials transportation regulations.

RCRA Docket Information Center

(RIC)

U.S. Environmental Protection

Agency

RCRA Docket Information Center

(5305W)

1200 Pennsylvania Ave, NW.

Washington, DC 20460

Phone: 703 603-9230

Fax: 703 603-9234

E-mail: RCRA-Docket@

epamail.epa.gov

Web: www.epa.gov/epahome/

dockets.htm

Provides public access to all regulatory materials on solid waste and

distributes technical and nontechnical information on solid waste.

Pollution Protection Information

Clearinghouse (PPIC)

U.S. Environmental Protection

Agency

1200 Pennsylvania Ave, NW.

Washington, DC 20460

Phone: 202 260-4659

Fax: 202 260-0178

E-mail: PPIC@epamail.epa.gov

Web: www.epa.gov/opptintr/

library/libppic.htm

Provides a library and an electronic

bulletin board (accessible by any

PC equipped with a modem) dedicated to information on pollution

prevention.

Information Resource Center

U.S. Environmental Protection

Agency

Headquarters Library

1200 Pennsylvania Ave, NW.

IRC (3404)

Washington, DC 20460

Phone: 202 260-5922

Fax: 202 260-5153

E-mail: public-access@

epamail.epa.gov

Web: www.epa.gov/natlibra/hairc

Maintains environmental reference

materials for EPA staff and the

general public, including books,

journals, abstracts, newsletters,

and audio-visual materials generated by government agencies and

the private sector.

Methods Information

Communication Exchange (MICE)

U.S. Environmental Protection

Agency

OSW Methods Team

1200 Pennsylvania Ave, NW.

(5307W)

Washington, DC 20460

Phone: 703 676-4690 or 

703 308-8855

Fax: 703 318-4682 or 

703 308-0511

E-mail: mice@cpmx.saic.com

Web: www.epa.gov/sw-846
24

EPA Regional Offices

EPA Region 1

CT, MA, ME, NH, RI, VT

1 Congress Street

Suite 1100

Boston, MA 02114-2023

617 918-1111 or

800 372-7431 in Region 1

Library: 888 372-5427 or 

617 918-1990

EPA Region 2 

NJ, NY, PR, VI

290 Broadway

26th Floor

New York, NY 10007-1866

212 637-3000

Library: 212 637-3185

EPA Region 3 

DC, DE, MD, PA, VA, WV

1650 Arch Street

Philadelphia, PA 19103-2029

215 814-5000 or

800 438-2474 in Region 3

Library: 215 814-5254

EPA Region 4

AL, FL, GA, KY, MS, NC, SC, TN

Atlanta Federal Center

61 Forsyth Street, SW

Atlanta, GA 30303-3104

404 562-9900

800 241-1754 in Region 4

Library: 404 562-8190

EPA Region 5

IL, IN, MI, MN, OH, WI

77 West Jackson Boulevard

Chicago, IL 60604

312 353-2000 or

800 621-8431 in Region 5

EPA Region 6 

AR, LA, NM, OK, TX

1445 Ross Avenue

Suite 1200

Dallas, TX 75202-2733

214 665-2200 or

800 887-6063 in Region 6

Library: 214 665-6424

EPA Region 7

IA, KS, MO, NE

901 North 5th Street

Kansas City, KS 66101

913 551-7000 or

800 223-0425 in Region 7

Library: 913 551-7241

EPA Region 8 

CO, MT, ND, SD, WY, UT

One Denver Place

999 18th Street

Suite 500

Denver, CO 80202-2466

303 312-6312 or

800 227-8917 in Region 8

EPA Region 9 

AS, AZ, CA, GU, HI, MH, MP, NV

75 Hawthorne Street

San Francisco, CA 94105

415 744-1305

Library: 415 744-1510

EPA Region 10 

AK, ID, OR, WA

1200 Sixth Avenue

Seattle, WA 98101

206 553-1200 or

800 424-4372 in Region 10

Library: 206 553-1289
25

Worksheet 3 These questions are geared toward the federal requirements for SQGs but may be helpful for other

hazardous waste generators. Use them to help prepare for a visit from a federal, state, or local agency.

Yes No

❑ ❑ Do you have documentation on the amount and kinds of hazardous waste that you generate and on how

you determined that they are hazardous?

❑ ❑ Do you have a U.S. EPA identification number?

❑ ❑ Do you ship wastes off site?

❑ ❑ If so, do you know the name of the transporter and the designated TSDF that you use?

❑ ❑ Do you have copies of completed manifests used to ship your hazardous wastes over the past 3 years?

❑ ❑ Are they filled out correctly?

❑ ❑ Have they been signed by the designated TSDF and transporter?

❑ ❑ If you have not received your signed copy of the manifest from the TSDF, have you filed an exception

report?

❑ ❑ Is your hazardous waste stored in proper containers or tanks?

❑ ❑ Are the containers or tanks properly dated and/or marked?

❑ ❑ Have you complied with the handling requirements described in this handbook?

❑ ❑ Have you designated an emergency coordinator?

❑ ❑ Have you posted emergency telephone numbers and the location of emergency equipment?

❑ ❑ Are your employees thoroughly familiar with proper waste handling and emergency procedures?

❑ ❑ Do you understand when you need to contact the National Response Center?

❑ ❑ Do you store your waste for no more than 180 days, or 270 days if you ship your waste more than 200

miles?
26

Byproduct

A material that is not one of the

primary products of a production

process. Examples of byproducts

are process residues such as slags

or distillation column bottoms. 

CESQG—Conditionally

Exempt Small Quantity

Generator

A business that generates less

than 220 lbs (100 kg) per month

of hazardous waste.

CFR—Code of Federal

Regulations

The CFR is a codification of the

general and permanent rules published in the Federal Register by

the Executive departments and

agencies of the federal government. The CFR is divided into 50

“titles,” which represent broad

areas subject to federal regulation.

Each title is divided into chapters,

which usually bear the name of the

issuing agency.

Commercial Chemical

Product

A chemical substance that is manufactured or formulated for commercial or manufacturing use.

Container

Any portable device in which a

material is stored, transported,

treated, disposed of, or otherwise

handled.

DOT—Department of

Transportation

Federal agency that oversees all

national transportation systems

and regulates the transport of

hazardous materials.

Elementary Neutralization

Unit 

A tank, tank system, container,

transport vehicle, or vessel (including ships) that is designed to contain and neutralize corrosive

waste.

Implementing Agency

EPA regional office or state agency

responsible for enforcing the hazardous waste regulations.

Incompatible Waste

A hazardous waste that can cause

corrosion or decay of containment

materials, or is unsuitable for comingling with another waste or

material because a dangerous

reaction might occur. See 40 CFR

Part 265, Appendix V for more

examples.

LDR—Land Disposal

Restrictions

The LDR program ensures that

toxic constituents present in hazardous waste are properly treated

before hazardous waste is disposed of in the land (such as in a

landfill).

ACRONYMS AND DEFINITIONS
27

LQG—Large Quantity

Generator

A business that generates more

than 2,200 lbs (1,000 kg) per

month of hazardous waste.

MICE—Methods Information

Communication Exchange

The MICE service provides

answers to questions about test

methods used to determine

whether a waste is hazardous. It

also takes comments on technical

issues regarding EPA’s methods

manual known as Test Methods for

Evaluating Solid Waste:

Physical/Chemical Methods (SW846). 

MSDS—Material Safety Data

Sheets

Chemical manufacturers and

importers prepare detailed technical bulletins called Material Safety

Data Sheets about the hazards of

each chemical they produce or

import. Your suppliers must send

you an MSDS at the time of the

first shipment of a chemical and

any time the MSDS is updated

with new and significant information about the hazards. MSDSs

include information about components and contaminants, including

exposure limits, physical data, fire

and explosion hazard, toxicity, and

health hazard data. It also discusses emergency and first aid procedures and information about

storage and disposal, and spill or

leak procedures.

NFPA—National Fire

Protection Association

NFPA’s mission is to reduce the

worldwide burden of fire and other

hazards on the quality of life by

providing and advocating scientifically based codes and standards,

research, training, and education.

NFPA has specific rules for storing

hazardous wastes.

PBT—Persistent,

Bioaccumulative, and Toxic

Persistent chemicals are those

that don’t readily break down in

the environment and can be transferred among air, water, soils, and

sediments. Bioaccumulative chemicals are those that concentrate in

animal and plant tissues as a

result of uptake from the surrounding environment or as a result of

one organism consuming another.

Toxic chemicals, in this context,

are those that are hazardous to

human health and the environment. EPA has been tasked with

focusing on reducing the toxicity of

wastes in addition to the quantity

of waste, and its Waste

Minimization National Plan focuses

on reducing PBT wastes.

POTW—Publicly Owned

Treatment Works

A municipal wastewater treatment

plant that receives wastewater

through the public sewer from

households, office buildings, factories and industrial facilities, and

other places where people live and

work.

Reclaimed Material

Material that is regenerated or

processed to recover a usable

product. Examples are the recovery of lead values from spent batteries and the regeneration of

spent solvents.

Recovered Material

A material or byproduct that has

been recovered or diverted from

solid waste. Does not include

materials or byproducts generated

from, and commonly used within,

an original manufacturing process. 

Recycled Material

A material that is used, reused, or

reclaimed.

Reused Material

A material that is employed as an

ingredient in an industrial process

to make a product, or is used as

an effective substitute for a commercial product.

Spent Material

Any material that has been used

and, as a result of contamination,

can no longer serve the purpose

for which it was produced without

first processing it.

SQG—Small Quantity

Generator

A business that generates

between 220 and 2,200 lbs (100

and 1,000 kg) per month of hazardous waste.
28

Sludge

Any solid, semi-solid, or liquid

waste generated from a municipal,

commercial, or industrial wastewater treatment plant, water supply

treatment plant, or air pollution

control facility, exclusive of the

treated effluent from a wastewater

treatment plant.

Still Bottom

Residue or byproduct of a distillation process such as solvent

recycling.

Tank

A stationary device designed to 

contain an accumulation of hazardous waste and that is constructed primarily of nonearthen

materials (e.g., wood, concrete,

steel, plastic).

Totally Enclosed Treatment

Facility

A facility for the treatment of 

hazardous waste that is directly 

connected to an industrial production process and that is constructed and operated to prevent the

release of hazardous waste into

the environment during treatment.

An example is a pipe in which

waste acid is neutralized.

TCLP—Toxicity

Characteristic Leaching

Procedure

A testing procedure used to determine whether a waste is hazardous. The procedure identifies

waste that might leach hazardous

constituents into ground water if

improperly managed.

TSDF—Treatment, Storage,

and Disposal Facility

Refers to a facility that treats,

stores, or disposes of hazardous

waste; TSDFs have specific

requirements under RCRA.

VOCs—Volatile Organic

Compounds

VOCs are highly evaporative organic gases that can be produced during the manufacture or use of

chemicals such as paints, solvents, and cleaners. Various pollution control devices can prevent

the release of VOCs both outdoors

and indoors.

Wastewater Treatment Unit

A tank or tank system that is subject to regulation under either

Section 402 or 307(b) of the

Clean Water Act, and that treats or

stores an influent wastewater that

is hazardous waste, or that treats

or stores a wastewater treatment

sludge that is hazardous.
1EPA

United States Environmental Protection Agency (5305W)Washington, DC 20460Official BusinessPenalty for Private Use $300