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Cal DTSC Answers FAQ About Generator Category Determination

Posted on 7/22/2024 by Lion Technology Inc.

California DTSC recently released an FAQ to help hazardous waste generators comply with revised and re-organized regulations that took effect on July 1, 2024.

"FAQ" #3 on the California GIR page relates to how a generator must determine its generator category for a calendar month under the state's updated hazardous waste regulations.

View the FAQ on DTSC's website.

1. How must a hazardous waste generator determine its generator category (e.g. either Large or Small Quantity Generator) for a calendar month?

The generator must count the total quantity of all hazardous wastes generated and categorize the total quantity of each type of hazardous waste generated in a calendar month. This includes acute hazardous waste, non-acute hazardous waste, and extremely hazardous waste. The generator must not count any waste that is exempt from the hazardous waste counting requirements . The generator then determines whether it is either a large quantity generator or a small quantity generator based on the total amount of hazardous waste they generate in a calendar month.

California’s VSQGs must follow the SQG rules. However, the program does include certain statutory and regulatory provisions for those that generate VSQG quantities of hazardous waste, such as ability to utilize household hazardous waste facilities for disposal.

Quantity of acute hazardous waste generated in a calendar month Quantity of extremely hazardous waste generated in a calendar month Quantity of non-acute hazardous waste generated in a calendar month Generator Category
> 1kg Any amount Any amount Large quantity generator
Any amount > 1kg Any amount Large quantity generator
Any amount Any amount ≥ 1,000 kg Large quantity generator
≤ 1 kg ≤ 1 kg < 1,000 kg Small quantity generator
≤ 1 kg   ≤ 100 kg Very small quantity generator

2. Do I have to document or record hazardous waste generator category determination decision each month?

No. There is no requirement to document this decision.

3. Can a generator’s category change month-to-month based on the amount of hazardous waste generated?

Yes, a generator’s category is based on the amount of hazardous waste they generated each calendar month and can change on a month-to-month basis.

Lion Members can see a more extensive breakdown of the changes that came with California's adoption of the GIR in the 4-page exhibit added to Lion.com/Members.

Expert-led Title 22/RCRA Refresher Training

Training with Lion in 2024 gives you an extra advantage: Lion instructors are well-versed in the RCRA Generator Improvements and how they affect generators in California. Lion has been updating and refining our hazardous waste training programs to address the new requirements since US EPA enacted them nearly a decade ago.

Check the schedule of upcoming instructor-led training (workshops and live webinars) to get up to speed before the new, stronger standards take effect.

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