How to Comply: Requirements for Very Small Quantity Generators (VSQGs) Federal Requirements.

If you generate no more than 220 lbs. (100 kg) of hazardous waste per month, you are a Very Small Quantity Generator (VSQG). You must comply with three basic waste management requirements to remain exempt from the full hazardous waste regulations that apply to generators of larger quantities (SQGs and LQGs). (Note: there are different quantity limits for acutely hazardous waste.)

• Identify your hazardous waste.

• Comply with storage quantity limits

• Ensure proper treatment and disposal of your waste.

First, you must identify all hazardous waste that you generate. Second, you may not store more than 2,200 lbs. (1,000 kg) of hazardous waste on site at any time. Finally, you must ensure delivery of your hazardous waste to an offsite treatment or disposal facility that is one of the following, or, if you treat or dispose of your hazardous waste on site, your facility also must be:

• A state or federally regulated hazardous waste management treatment, storage, or disposal facility (TSDF).

• A facility permitted, licensed, or registered by a state to manage municipal or industrial solid waste.

• A facility that uses, reuses, or legitimately recycles the waste (or treats the waste prior to use, reuse, or recycling).

• A universal waste handler or destination facility subject to the universal waste requirements (40 CFR Part 273).

As a VSQG, under federal rules, you do not subject to other aspects of RCRA, such as obtaining an EPA identification number, or meeting storage requirements. However, you may be regulated by state rules (see below) that have these requirements. Also, you may want to use the RCRA rules as guidelines for the responsible management of hazardous waste.

State Requirements
Some states have additional requirements for VSQGs. For example, some states require VSQGs to follow some of the SQG requirements such as obtaining an EPA identification number or complying with storage standards.

It's a good idea to call the appropriate state agency to verify that the treatment, storage, and disposal facility (TSDF) you have selected has any necessary permits, etc. You also may want to see that the facility fits into one of the above categories. (It's a good idea to document such calls for your records.) To find your state agency, use the ENVCAP State Agency Locator. Also, EPA maintains webpage that identifies differences in state hazardous waste generator categories.

More Resources
Summary of Requirements for Very Small Quantity Generators (EPA fact sheet).