Paints & Coatings Resource Center

Plain Language Guide to Regulations
Solid/Hazardous Waste Management

How to Comply. Determine Your Generator Category (VSQG, SQG, LQG)

Knowing your waste category is important because it can affect which regulations apply to your facility.

EPA defines three categories of hazardous waste generators based upon the quantity of hazardous waste they generate per month:

  1. Very small quantity generators (VSQGs), which generate less than 220 lbs. (100 kg) per month. [Important note: Not all states recognize the VSQG category. State generator categories can be different than the federal categories. Please see the differences in hazardous waste generator categories table.]

  2. Small quantity generators (SQGs), which generate between 220 lbs. (100 kg) and 2,200 (1,000 kg) per month.

  3. Large quantity generators (LQGs), which generate more than 2,200 lbs. (1,000 kg) per month.

Some RCRA and state rules are the same for all categories and in other cases the rules vary. In this plain language guide, we point out significant differences in the rules that affect painting operations.

If you are a VSQG and you generate no more than 2.2 lbs. (1 kg) of "acute hazardous waste" (or 220 lbs. (100 kg) of acutely hazardous waste spill residues) in a calendar month, and never store more than that amount for any period of time, you may manage the acutely hazardous waste according to the VSQG requirements. If you generate more than 2.2 lbs. (1kg) of acutely hazardous waste, you must manage it according to the LQG requirements.

Depending on your business, you might be regulated under different rules at different times. If, for example, you generate less than 220 lbs. (100 kg) of hazardous waste during the month of June, you would be considered a VSQG for June and your June waste would be subject to the hazardous waste management requirements for VSQGs. If, in July, you generate between 220 and 2,200 lbs. (100 kg to 1,000 kg) of hazardous waste, your generator status would change, and you would be considered an SQG for July. Your July waste would then be subject to the management requirements for SQGs.

*TIP: In many cases, small businesses that fall into different generator categories at different times choose to satisfy the more stringent requirements to simplify compliance.

Check HERE to find out what you measure to determine your generator category.


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