If your business is a small quantity generator (SQG) of hazardous waste, you need to re-notify your status with the Environmental Protection Agency or your state environmental agency by September 1, 2021. If that sounds like a brand-new deadline that is about to give you some heartburn, don’t worry, we’ve got a breakdown of what you need to know so it’s not too overwhelming.
Is This New?
This is the first re-notification due date to come up, as a result of the 2016 Hazardous Waste Generator Improvement Rule.
The rule states that all SQGs need to let the EPA know about their hazardous waste status every four years as a way to improve and maintain more accurate data about the generator facility, improve generator compliance, and ensure proper regulatory oversight. September 1, 2021, is the first deadline under this new rule. Subsequent re-notification deadlines will be September 1, 2025, September 1, 2029, etc.
The re-notification is completed by submitting the Notification of Resource Conservation and Recovery Act (RCRA) Subtitle C Activities (Site Identification Form) in full, also known as EPA Form 8700-12, or the state equivalent of the form.
Do I have to Send In My Hazardous Waste Generator Status?
This re-notification only applies to Small Quantity Generators (SQG). It’s also going to depend on what state your facility(s) is located in. Below we’ve mapped out the states where this rule has been adopted or has been authorized.
In either scenario, you’ll want to confirm with your state agency that this is a requirement, the frequency of re-notification, and you’ll need to submit the state equivalent of the re-notification form.
An SQG produces between 100 kilograms – 1,000 kilograms (220 lbs – 2,200 lbs) of hazardous waste per month. If you’re not sure about your current status, you should conduct an EPA FRS Query for your facility.
If you’re looking for a previous record, use your address or your company name to find the record and the date. Your records might be out of date and need to be updated, also part of the reason this re-notification is in place.
Once you find your business, you should be able to identify if there is a Resource Conservation and Recovery Act Information System entry with a corresponding EPA ID # and Generator Status (VSQG, SQG, or LQG).
If you are registered as an SQG, then you can choose to submit Form 8700-12 with the federal paper form, state equivalent, or the online version using MyRCRAid. Here is where you’ll update your contact information and potentially your generator status. You’ll need to review the amount of hazardous waste your facility generates and have that readily available.
If you’re a KPA customer, your Consultant can help you fill out this form.
If You're A Very Small Quantity Generator (VSQG)
You don’t need to submit a re-notification to the EPA. It’s a best practice to review your generator status, so this might be a good opportunity to review your hazardous waste output and ensure your status remains the same.
If You're A Large Quantity Generator (LQG)
You don’t need to submit a re-notification to the EPA this year. While the re-notification requirement still applies to your facility, re-notification must be submitted by March 1st of even numbered years and is generally completed during the submission of your biennial report.
Hazardous Waste Generator Status Breakdown
With all this talk about generator status, here’s a breakdown of the categories and amounts of hazardous waste:
|Very Small Quantity Generator||Small Quantity Generator||Large Quantity Generator|
|Less than 220 lbs/ month||Greater than 220 and |
less than 2,200 lbs/ month
|Greater than 2,200 lbs/ month|
KPA is Here to Help
KPA clients should reach out to their Consultants for additional guidance and input.