Hazardous waste is generated by many types of industries. It is regulated by EPA under the Resource Conservation and Recovery Act (RCRA), which was passed in 1976. Under the act, for a waste to be classified as hazardous, it must first meet the RCRA definition of “solid waste,” which is defined as any discarded material that is not excluded under 40 CFR Part 261.4(a). If the material is considered a “solid waste” under RCRA, it must then be determined if the waste is listed or characteristic hazardous waste under 40 CFR Part 261, Subparts C and D.
Once it has been determined that the waste is a “hazardous waste,” the generator of the hazardous waste can be classified according to the amount of hazardous waste generated (not disposed) each month. The generator status classifications include:
- Large Quantity Generators (LQG) – generate ≥1,000 kg (2,205 lbs) of hazardous waste per month.
- Small Quantity Generators (SQG) – generate >100 kg (220.5 lbs) and <1,000 kg (2,205 lbs) of hazardous waste per month.
- Very Small Quantity Generators (VSQG) – generate ≤100 kg (220.5 lbs) of hazardous waste per month.
Each generator classification has its own requirements, including on-site accumulation quantity limits of hazardous waste (≤1,000 kg for LQG and ≤6,000 kg for SQG), accumulation time limits of hazardous waste (90-days for LQG and 180-days for SQG), training requirements, requirements for Hazardous Waste Contingency Plans, reporting requirements, etc.
Hazardous Waste Contingency Plans are required for LQG and SQG. Requirements for Contingency Plans are further detailed below for each:
- SQG – A basic plan is required in accordance with 40 CFR Part 262.16(b)(9), which includes:
- the name and emergency telephone number of the emergency coordinator;
- location of fire extinguishers, spill control materials, and fire alarms; and
- the telephone number of the fire department.
The plan must be posted next to telephones or in areas directly involved in the generation and accumulation of hazardous waste.
- LQG – A full plan is required in accordance with 40 CFR Part 262.261, which includes:
- details of emergency actions to be taken in response to fires, explosions, or any unplanned sudden or non-sudden release of hazardous waste to air, soil, or surface water;
- arrangements made with local police department, fire department, other emergency response teams, emergency response contractors, equipment suppliers, local hospitals or, if applicable, the Local Emergency Planning Committee (LEPC);
- the name and emergency telephone number of the emergency coordinator,
- a list of all emergency equipment at the facility (such as fire extinguishing systems, spill control equipment, communications and alarm systems (internal and external), and decontamination equipment), including the location, physical description, and a brief outline of the capabilities of each;
- an evacuation plan for personnel; and
- a Quick Reference Guide for all emergency responders with the required components identified in 40 CFR Part 262.262(b).
For questions about Contingency Plans or any other Hazardous Waste requirements, contact Environmental Compliance & Safety, Inc. at:
- Phone: (662) 840 5945
- Website: https://envirocomp.net/contact/
