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If your facility produces any kind of hazardous waste, you need to be aware of your EPA generator status and how to legally avoid registering – and paying the fees of - a large quantity generator. The large quantity status also comes with plenty of additional regulations and paperwork to ensure compliance with federal and state laws. Taking certain steps can reduce your classification as a large quantity generator – saving you money, hassle, and paperwork.
01 / What is a Large Quantity Generator?
The Environmental Protection Agency classifies hazardous waste generator status by the volume of hazardous waste produced in one month’s time. For example:
- Very small quantity generators (VSQG) – generate less than 100 kg (approx. 220 lbs.) of hazardous waste or less than one (1) kg of acutely hazardous waste per month.
- Small quantity generators (SQG) – generates more than 100 kg (approx. 220 lbs.) of hazardous waste but less than 1,000 kg per month.
- Large quantity generators (LQG) – generate 1,000 kg (approx. 2,204 lbs.) or more of hazardous waste per month or more than one (1) kg of acutely hazardous waste per month.
Additional rules and storage time restrictions apply to each category.
A LQG applies to any business that produces hazardous materials over 2,200 pounds per month. If this level is reached or exceeded, that business faces higher waste disposal fees, regulations and paperwork. Avoid having to file as such—unless absolutely necessary.
When filing as a hazardous waste generator, the type and amount of waste you’re generating and your physical location will be needed to file not only your EPA generator status but also to apply for an EPA identification number. The EPA ID number is required for all hazardous waste generators and is also needed for transportation of such waste. The EPA ID number must be present on all relevant paperwork.
02 / Can You Circumvent a Large Quantity Generator Classification?
Some businesses produce so much hazardous material that they must legally register with that large quantity status and are unable to avoid that classification. For such businesses, it is not a matter of improper waste segregation or implementing waste practices that needlessly bump them into that large status. Due to the volume of hazardous waste they manufacture or produce in their operations, they have no choice but to register as a LQG. Failure to register as such is a violation of the law that might result in serious fines.
03 / What do Federal and State Regulations say about Kentucky Hazardous Waste Contingency Planning?
A number of steps, waste management tips and best practices might help you from needlessly reaching the large quantity generator status.
Waste Minimization - One of the most straightforward ways to avoid that 2,200-pound-per-month limit is by trying to minimize generation of hazardous waste. This often involves using non-hazardous alternatives to potentially hazardous materials.
For example, if you’re dealing with paint or ink, go with a non-hazardous (or, at least, less hazardous) variety. Using latex paint or water-based paint over oil-based paint or solvent-based paint can greatly reduce your hazardous output. An experienced, reputable hazardous waste disposal company will be able to walk you through this process and create a customized plan for you and your business.
Waste minimization is a benefit of improved waste management processes over time. An auto body shop that produced twenty to thirty drums of waste in the early nineties might only produce one or two drums today due to improved machines and equipment, more prevalent use of non-hazardous chemicals or biodegradable chemicals, and so forth.
Proper Waste Segregation - Segregation of waste is key, but is an aspect of waste management that employees often neglect. However, if an employee puts even one ounce of hazardous waste into a drum of non-hazardous waste, that entire drum is now classified as hazardous waste. Therefore, always keep hazardous and non-hazardous waste in separate containers. Some employees might be tempted to put their hazardous materials into a non-hazardous bin just to fill it to the top for shipment, but again, that means that entire bin is now hazardous waste.
Employee Education - To ensure hazardous waste processes are compliant, every employee must be educated about federal, state, and county laws regarding hazardous waste management, best practices, and company policies regarding its storage and disposal. If one employee doesn’t know and improperly segregates that waste, it can push your company over the limit and you’ll be required to register at that higher generator status.
Improved education across all levels, from management to floor, also helps to ensure best practices, such as using every bit of a chemical or product rather than simply throwing the excess into accumulated waste.
The global trend these days is toward waste minimization because it’s better for the environment, safety for people and wildlife, and a more sustainable future. Make sure your employee understand this and can contribute in all ways possible.
04 / Why Work with a Hazardous Waste Removal Company?
If your business or facility consistently hovers on the edge of having to register in the large quantity waste generator category, working with a professional and experienced hazardous waste management company like MCF Environmental Services can identify practices that might keep you below the LQG volume limits. If the company can successfully help you avoid this, they’ve already made themselves financially worth it.
You also get peace of mind knowing you have the help of experts in dealing with hazardous or otherwise dangerous materials. As the generator, you assume the ‘cradle to grave’ liability, meaning you, and only you, are the sole entity responsible for compliant hazardous waste management from its generation to its final disposal. Be sure that you’re handling this type of waste safely and legally all the way through to disposal.
For more information about generator status and how a hazardous waste disposal company can possibly save you money in this regard, contact a representative of MCF Environmental Services, a full-service Atlanta-based hazardous waste management company.
Robert Losurdo
President, COO
