How to Determine RCRA Generator Status

Any person who produces hazardous waste or causes hazardous waste to become subject to regulation is a hazardous waste generator, or generator for short. A generator can be an individual, but more generally, the term applies to a facility or site. The amount of hazardous waste generated or accumulated at a site during a calendar month determines its generator status/category.

Under the Federal environmental regulations, there are three generator categories: very small quantity generator, small quantity generator, and large quantity generator. Knowing your generator category is crucial, because the more waste you generate, the more rules you have to follow.

Check your State's rules before making compliance decisions. Not all states recognize these categories and some have stricter generation/accumulation limits. 

Effects of a Changing Generator Status

Because RCRA lists separate generator status thresholds for non-acute hazardous waste, acutely hazardous waste, and spill clean-up materials from acutely hazardous waste, it’s not unusual for a site's generator status to change. And if your generator status changes from SQG to LQG, for example, your site is covered by more stringent regulations. More stringent regulations for LQGs cover training requirements, Biennial Reports, and even how long you are allowed to accumulate hazardous waste on site.

On March 1 of every even-numbered year, large quantity generators must submit a Biennial Report that includes details about hazardous waste management activities during the previous calendar year.

If a facility meets the LQG threshold (see the above table) during even a single month of 2027, and does not qualify for regulatory relief via Episodic Generation, then it must file a report in 2028 for all of the waste generated the previous year. The report must describe all the hazardous waste that was generated at the facility, how much was generated, and what happened to it.

Best practice is to keep good records of your waste generation every month, even if you’re normally a small quantity generator or even a very small quantity generator.

RCRA compliance can be a rocky road. Ensure you are always in compliance with accumulation rules with effective RCRA training. At Lion’s RCRA Hazardous Waste Management, you’ll learn how to classify hazardous waste, determine your on-site storage options, count hazardous wastes, and more.

RCRA Training Requirements by Generator Status

Your generator status is the single biggest factor in what your RCRA training program must look like. The Federal requirements differ significantly across the three categories: large quantity generators (LQGs), small quantity generators (SQGs), and very small quantity generators (VSQGs). Some states have different categories and/or different names for them.

See what hazardous waste generator training programs must look like in more detail here:

• RCRA Training: A Complete Guide for Hazardous Waste Generators
• RCRA Training Requirements for LQGs
• RCRA Training Requirements for SQGs
• RCRA Training Requirements for VSQGs

Tags: biennial report, hazardous waste management, RCRA