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Regulation of Hazardous Waste Generators

Hazardous waste is regulated through the Resource Conservation and Recovery Act (RCRA).  There are three categories of handlers for hazardous waste including
(1) generators, (2) transporters, and (3) treatment and management facilities. 

Hazardous waste generators and transporters are required to file a public notice and acquire an EPA tracking identification number through the Washington State Department of Ecology.  Hazardous waste treatment and management facilities must apply for a two-part hazardous waste permit.

Generators are handlers that produce hazardous waste, usually generated from an industrial process.  There are three categories of generators briefly described below.

• Conditionally Exempt Small Quantity Generators (CESQG) ) generate less than 100 kg of hazardous waste, or less than 1 kg of acutely hazardous waste per month.  Requirements for CESQGs include identifying all hazardous waste they generate, not accumulating more than 1000kg of hazardous waste at any time, and delivering hazardous waste to a handler that is authorized to manage their waste.  For more detailed information about CESQGs see 40 CFR 261.5.
  
• Small Quantity Generators (SQG) generate between 100 kg and 1,000 kg of hazardous waste per month.  Requirements for SQGs include acquiring an EPA identification number, packaging and labeling of hazardous wastes properly before transporting, following the requirements for the tracking system (from generation to final disposal), and keeping records of their activities.  For more detailed information about SQGs see 40 CFR 262.
  
• Large Quantity Generators (LQG) generate over 1,000 kilograms (kg) of hazardous waste, or over 1 kg of acutely hazardous waste per month.  Requirements for LQGs include acquiring an EPA identification number, packaging and labeling of hazardous wastes properly before transporting, following the requirements for the tracking system (from generation to final disposal), and keeping records of their activities.  For more detailed information about LQGs see 40 CFR 262.

Transporters are handlers that move hazardous waste from the generator to a facility that can treat and manage the waste.  The generator must prepare a shipping document, called a manifest, which accompanies the waste to its final destination and is used to track the waste from generation to disposal or treatment.  Transporters must acquire an EPA Identification number through the Washington State Department of Ecology, follow the requirements for the tracking system (from generation to final disposal), respond to hazardous waste discharges, and meet the requirements for both the RCRA (40 CFR Part 263) and the Department of Transportation (49 CFR Parts 171-179).