Independent guide published by Wastetide. Not affiliated with, endorsed by or operated by the U.S. EPA or its e-Manifest system. For official filings use EPA's official e-Manifest website.
Key takeaways
- Status is determined monthly by the quantity of hazardous waste generated, not stored.
- VSQG: 100 kg or less per month (and 1 kg or less of acute hazardous waste).
- SQG: more than 100 kg and less than 1,000 kg per month.
- LQG: 1,000 kg or more per month, or more than 1 kg of acute hazardous waste.
- States can be stricter than the federal rules: always check your state program.
Federal categories at a glance
VSQG
SQG
LQG
Monthly generation
≤ 100 kg
> 100 kg and < 1,000 kg
≥ 1,000 kg
Acute hazardous waste
≤ 1 kg
≤ 1 kg
> 1 kg
On-site accumulation
≤ 1,000 kg at any time
Up to 180 days (270 if facility > 200 miles), ≤ 6,000 kg
Up to 90 days
EPA ID number
Not federally required
Required
Required
Manifest
Per state rules
Required
Required
Reporting
None federally
Re-notification every 4 years
Biennial report
How to count
- List every hazardous waste stream and its monthly quantity.
- Count waste when it is generated, not when shipped.
- Exclude wastes that are exempt or managed as universal waste.
- Keep monthly records to justify your category.
- Plan for episodic events (cleanouts, decommissioning) that can temporarily change your status.
Data centers and plants: typical triggers
- Battery replacements managed outside universal waste rules.
- Solvent and paint waste from maintenance.
- Used oil and contaminated rags if not managed under used oil rules.
- Laboratory chemicals.
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FAQ
Can a site change category from month to month?
Yes. Status is determined each calendar month, and episodic generation provisions cover certain planned or unplanned events.