The Complete Guide to Small Quantity Generators (SQGs): Requirements, Compliance, and Best Practices
The Complete Guide to Small Quantity Generators (SQGs): Requirements, Compliance, and Best Practices
Last Updated: January 2026
If your business generates between 100 and 1,000 kilograms of hazardous waste per month, you're classified as a Small Quantity Generator (SQG) under EPA regulations. This classification comes with significantly more regulatory requirements than Very Small Quantity Generators (VSQGs) but provides more flexibility than Large Quantity Generators (LQGs).
Understanding SQG requirements is critical for compliance, avoiding penalties, and managing your hazardous waste program efficiently. This comprehensive guide covers everything you need to know about SQG status, regulatory requirements, compliance strategies, and best practices.
What is a Small Quantity Generator (SQG)?
A Small Quantity Generator is the EPA's mid-tier classification for hazardous waste generators under the Resource Conservation and Recovery Act (RCRA). SQGs face moderate regulatory requirements balancing environmental protection with practical considerations for mid-sized operations.
SQG Definition and Thresholds
Your facility qualifies as an SQG if you generate:
Between 100 and 1,000 kilograms (220-2,200 pounds) per month of hazardous waste
AND
Less than 1 kilogram (2.2 pounds) per month of acutely hazardous waste (P-listed waste)
Practical perspective:
100 kg is approximately one-half full 55-gallon drum per month
1,000 kg is approximately five full 55-gallon drums per month
Most medium-sized manufacturing, automotive, maintenance, and service operations fall into SQG category
Key Difference from VSQGs and LQGs
Compared to VSQGs (<100 kg/month):
SQGs have MORE requirements: EPA ID number mandatory, manifesting required, accumulation time limits, training needed
Additional compliance costs and administrative burden
More regulatory scrutiny
Compared to LQGs (≥1,000 kg/month):
SQGs have LESS stringent requirements: longer accumulation times (180/270 days vs. 90 days), simpler training, no biennial reporting
Lower compliance burden
More regulatory flexibility
Critical Threshold Management: Most businesses prefer staying SQG rather than becoming LQG. Generating 999 kg vs. 1,001 kg per month makes enormous difference in regulatory requirements. We'll discuss threshold management strategies later.
Who Typically Qualifies as an SQG?
Mid-sized operations across numerous industries commonly qualify as SQGs.
Manufacturing Operations
Metal Fabrication and Machine Shops:
Parts washing solvents (multiple parts washers)
Cutting fluids and coolants
Hydraulic fluids from equipment
Painting and coating operations
Degreasing solvents
20-50 employee shops commonly SQGs
Small to Medium Manufacturers:
Specialty chemical production
Electronics assembly and manufacturing
Plastics fabrication and molding
Food processing equipment cleaning
Pharmaceutical contract manufacturing
Assembly operations with painting/coating
Commercial printing companies
Screen printing operations
Lithographic printers
Printing inks and fountain solutions
Press wash solvents
Plate development chemicals
Automotive and Transportation
Auto Dealerships with Service Departments:
New car dealerships with repair bays
Used car lots with reconditioning
Fleet maintenance facilities
Multiple service bays generating:
Used oil and filters
Antifreeze and coolants
Solvents and degreasers
Paint and body shop waste
Brake fluids and transmission fluids
Truck and Fleet Maintenance:
Trucking company maintenance shops
Bus fleet maintenance
Municipal vehicle maintenance
Delivery fleet service centers
Auto Body Shops (Larger Operations):
Multi-bay collision repair
Paint booths and refinishing
Substantial paint waste generation
Solvents and thinners
Body filler and resin waste
Educational Institutions
High Schools and Universities:
Chemistry and physics teaching laboratories
Research laboratories (smaller programs)
Maintenance department waste
Art department solvents and chemicals
Biology and life science labs
Multiple small waste streams totaling SQG quantities
Community Colleges and Technical Schools:
Automotive technology programs
Welding and fabrication programs
Chemical technology programs
Cosmetology programs (rare but possible)
Healthcare Facilities
Medium-Sized Hospitals (50-150 beds):
Laboratory chemical waste
Pharmaceutical waste (see our Pharmaceutical Waste page)
Pathology department formaldehyde
Radiology chemistry (declining with digital)
Maintenance department waste
Large Medical Clinics and Surgery Centers:
Multi-specialty clinics
Ambulatory surgery centers
Imaging centers with chemistry
Pathology laboratories
Veterinary Hospitals (Larger Operations):
Multi-doctor practices
Emergency and specialty veterinary hospitals
Veterinary teaching hospitals
Pharmaceutical and anesthetic waste
Industrial and Commercial Services
Multi-store operations
Industrial/commercial laundries
Perc or petroleum solvent operations
Solvent distillation waste
Industrial Cleaning and Maintenance Companies:
Industrial equipment cleaning
Tank cleaning services
Facilities maintenance contractors
Janitorial service companies (large)
Laboratories:
Environmental testing laboratories
Clinical reference laboratories (medium-sized)
Quality control laboratories
Research and development labs
Government and Institutional
Military Installations (Support Facilities):
Vehicle maintenance shops
Equipment repair facilities
Installation operations
City/county vehicle maintenance
Water treatment plants
Wastewater treatment facilities
Public works departments
Parks and recreation maintenance
Airports:
Aircraft maintenance (smaller operations)
Ground support equipment maintenance
Facility maintenance operations
SQG Requirements: Complete Compliance Checklist
SQGs must comply with multiple RCRA requirements. Here's your complete checklist:
1. Obtain an EPA Identification Number
REQUIRED - First step for all SQGs
What it is:
12-character identification number (format: ABC123456789)
Uniquely identifies your facility in EPA's hazardous waste tracking system
Required before first hazardous waste shipment as SQG
How to obtain:
Contact your state environmental agency (most states administer EPA ID program)
Complete EPA Form 8700-12 (Notification of Regulated Waste Activity) or state equivalent
Provide facility information (name, address, NAICS code, waste types)
Submit electronically through state system or mail paper form
Receive EPA ID number (typically 2-4 weeks)
Cost: Usually free or minimal fee ($25-$100 in some states)
Important: Using someone else's EPA ID number or operating without one is serious violation. Each physical location where hazardous waste is generated needs separate EPA ID number.
2. Accumulate Waste Within Time Limits
CRITICAL REQUIREMENT - Violations common
SQGs may accumulate hazardous waste on-site for:
180 Days if disposal facility is ≤200 miles away
OR
270 Days if disposal facility is >200 miles away
Accumulation "Clock" Starts:
When you FIRST add waste to container
NOT when container is full
Must mark accumulation start date on each container
If Time Limit Exceeded:
Facility becomes operating storage facility requiring permit
Significant penalties ($50,000+ per day per violation)
Immediate compliance action required
Extension Strategies:
Measure distance to permitted disposal facility
Most SQGs can qualify for 270-day extension (many facilities >200 miles from TSDFs)
Document distance measurement for inspections
Some states don't allow distance-based extension
Accumulation Quantity Limits: SQGs may accumulate up to 6,000 kg (13,200 lbs) on-site
Approximately thirty 55-gallon drums
If exceed this quantity, facility becomes operating storage facility requiring permit
3. Use Proper Containers and Labeling
Container Requirements:
Condition:
Good condition (no rust, leaks, severe dents)
Compatible with waste (plastic for corrosives, metal for solvents unless DOT allows plastic)
Structural integrity adequate for waste weight
Closed Containers:
Must be closed except when adding or removing waste
Lids secured
Bungs tight on drums
Compatible Materials:
Container material must not react with waste
Example: Don't store acetone in some plastics that dissolve
Check compatibility charts
DOT Specifications:
If transporting off-site, containers must meet DOT requirements
Look for DOT specification markings (e.g., "DOT 17E" on steel drums)
Labeling Requirements:
REQUIRED on every container:
"Hazardous Waste" label - clearly visible
Waste contents - description of waste (e.g., "Spent Solvent - Acetone" or "Paint Waste")
Accumulation start date - date first waste added to container (critical for time limit compliance)
Generator information - facility name (if container might leave accumulation area)
Optional but recommended:
EPA waste codes (D001, F003, etc.)
Hazard warnings (flammable, corrosive, toxic)
Physical state (liquid, solid)
Example compliant label:
HAZARDOUS WASTE
Contents: Spent Degreasing Solvent
Accumulation Start Date: 01/15/2026
Generator: ABC Manufacturing
4. Store Waste in Designated Accumulation Areas
Accumulation Area Requirements:
Location:
At or near point of waste generation
Within facility control
Away from incompatible materials
Protected from weather (if outdoors, use covered or weatherproof containers)
Secondary Containment:
Required for liquids in containers
Must hold 110% of largest container OR 10% of total volume, whichever is greater
Can be containment pallets, berms, double-walled containers, or concrete vaults
Must be impervious to waste being stored
Incompatibility:
Separate incompatible wastes (acids away from bases, oxidizers away from flammables)
Follow compatibility guidelines
Aisle Space:
Adequate space for inspections, spill response, emergency access
OSHA aisle space requirements apply
Fire code requirements
Access Control:
Limit access to authorized personnel
Prevent unauthorized entry
Signage identifying hazardous waste area
Weekly Inspections: While formal documented inspections aren't federally required for SQGs (unlike LQGs), they're best practice and required by some states. Inspect for:
Container condition and leaks
Label accuracy and legibility
Proper closure
Secondary containment integrity
Accumulation dates approaching limits
5. Manifest All Waste Shipments
REQUIRED - Critical compliance element
What is a Manifest? Uniform Hazardous Waste Manifest (EPA Form 8700-22) is multi-copy shipping document tracking hazardous waste from "cradle to grave."
Manifest Copies:
Generator keeps copy 2 (initial)
Transporter keeps copy (initial)
Designated facility (TSDF) keeps copy (initial)
Generator receives signed copy from TSDF proving receipt (copy 2 returned)
Required Information:
Generator name, address, EPA ID number
Transporter name and EPA ID number
Designated facility (TSDF) name and EPA ID number
Waste description (DOT shipping name and hazard class)
Waste quantity (pounds or kilograms)
Waste codes (D001, F003, etc.)
Generator certification and signature
Transporter and TSDF signatures
E-Manifest:
Electronic manifest system (e-Manifest) available since 2018
Can complete manifests electronically
Easier tracking and recordkeeping
Fee-based system ($5-$8 per manifest)
Optional - paper manifests still acceptable
Manifest Exception Reporting: SQGs must follow up if signed manifest copy not received:
Contact TSDF if copy not received within 60 days (45 days for LQGs)
Submit exception report to EPA/state if not received within 75 days (60 days for LQGs)
Documents must show:
Copy of original manifest
Efforts to locate waste
Result of investigation
Recordkeeping:
Retain manifest copies 3 years minimum
Longer retention recommended (5-7 years)
Make readily available for inspections
Organized filing system
6. Use Only Permitted Facilities
SQGs must send waste to:
Permitted hazardous waste treatment, storage, and disposal facilities (TSDFs)
Permitted recyclers
Universal waste facilities (for universal wastes)
Verify Facility Permits:
Request copy of TSDF permit
Verify permit covers waste types you're sending
Check EPA ID number
Confirm facility legitimacy
Never Use:
Unlicensed haulers or facilities
Suspicious "too good to be true" pricing
Operations with no verifiable permits
Facilities reluctant to provide documentation
7. Implement Personnel Training
REQUIRED for SQG employees handling hazardous waste
Who Needs Training:
All employees who handle hazardous waste
Personnel managing containers
Staff responding to spills
Waste coordinators
Facility managers overseeing program
Training Topics:
Hazardous Waste Management:
Waste identification and characterization
Container selection and management
Proper labeling procedures
Accumulation area requirements
Accumulation time limits
Emergency Procedures:
Spill response
Fire prevention and response
Emergency contacts and procedures
Evacuation procedures
Emergency equipment location and use
Safety and Personal Protective Equipment:
Hazards of wastes handled
Proper PPE selection and use
Safe handling practices
First aid procedures
Regulatory Requirements:
SQG regulations overview
Manifesting procedures
Recordkeeping requirements
Inspection procedures
Training Frequency:
Initial training before job assignment
Annual refresher training recommended (LQGs required, SQGs recommended)
When job responsibilities change
When new waste streams introduced
Documentation: SQGs must maintain training records including:
Employee name and job title
Training dates
Topics covered
Instructor name or training program description
Employee signature acknowledging training
Retain records for 3 years minimum
Training Methods:
Classroom training sessions
Online training programs
On-the-job training with documentation
Vendor-provided training
Industry association training programs
8. Prepare Basic Emergency Procedures
REQUIRED but less extensive than LQG requirements
SQGs must have emergency procedures in place but don't need formal written contingency plans like LQGs.
Emergency Procedures Must Address:
Emergency Coordinator:
Designate at least one employee as emergency coordinator
Must be familiar with facility operations
Authority to commit resources to emergencies
Available or on-call at all times
Emergency Equipment:
Fire extinguishers appropriate for waste types
Spill cleanup equipment (absorbents, neutralizers, PPE)
Internal communications equipment
External communications (phone, radio)
Emergency lighting
Eye wash and safety showers (where needed)
Emergency Response Actions:
Spill containment and cleanup procedures
Fire response (when to fight, when to evacuate)
Emergency notifications (internal and external)
Evacuation procedures
Emergency contacts list
Emergency Contacts:
911 or local emergency services
Fire department
State environmental emergency number
Facility emergency coordinator
Management contacts
Spill cleanup contractors
Disposal company emergency number
Spill Response:
Stop source if safe to do so
Contain spill preventing spread
Alert personnel and evacuate if necessary
Use appropriate PPE
Clean up using proper methods
Place contaminated materials in waste containers
Report if required (reportable quantities)
9. Maintain Required Records
SQGs must maintain:
Manifests: 3 years minimum
All copies of hazardous waste manifests
Exception reports
Annual summary (if multiple shipments)
Training Records: 3 years minimum
Employee training documentation
Training materials
Competency verification
Waste Determinations: No specified time, but keep indefinitely
Characterization data
Process knowledge documentation
Analytical results (if tested)
Waste code determinations
Inspection Records: Recommended even if not required
Accumulation area inspections
Container condition checks
Corrective actions
EPA ID Number Documentation:
Copy of notification form
EPA ID assignment letter
Best Practice: Maintain all records 5-7 years minimum. Electronic recordkeeping acceptable but ensure backups and accessibility.
SQG vs. VSQG vs. LQG: Critical Differences
Understanding regulatory differences helps manage your status strategically.
Comprehensive Comparison Table
Requirement VSQG SQG LQG Monthly Generation <100 kg 100-1,000 kg ≥1,000 kg Acutely Hazardous (P-listed) <1 kg/month <1 kg/month >1 kg/month Maximum On-Site Accumulation <1,000 kg <6,000 kg No federal limit EPA ID Number Not required Required Required Manifest Required No Yes - all shipments Yes - all shipments Accumulation Time Limit None federal 180 or 270 days 90 days Personnel Training Not required Required with records Required annually with comprehensive documentation Emergency Procedures Not required Basic procedures required Written contingency plan required Weekly Inspections Not required Recommended Required and documented Biennial Report No No Yes - March 1 every even year Preparedness and Prevention Not required Recommended Required Contingency Plan Not required Not required Required Recordkeeping Recommended 3 years minimum 3 years minimum (some records longer)
Financial Impact of Generator Status
Typical Annual Compliance Costs:
VSQG: $2,000-$8,000
Disposal costs only
Minimal administrative burden
No manifesting costs
No formal training programs
SQG: $5,000-$25,000
Disposal costs (higher volumes)
Manifesting and documentation
Basic training programs
Part-time environmental coordinator
Compliance assistance
LQG: $15,000-$100,000+
Substantial disposal costs
Full compliance program
Dedicated environmental personnel
Comprehensive training
Contingency planning
Biennial reporting
More frequent inspections
Higher insurance costs
Key Insight: Staying SQG vs. becoming LQG saves $10,000-$75,000 annually for typical mid-sized facility.
Managing Your SQG Status: Strategies and Best Practices
Staying Below the LQG Threshold (1,000 kg/month)
Many SQGs strategically manage waste generation to avoid LQG status.
Why Avoid LQG Status:
90-day accumulation limit (vs. 180/270 for SQG) creates logistical challenges
Comprehensive annual training requirements
Written contingency plan required
Biennial reporting to EPA
More frequent inspections by regulators
Higher compliance costs
Dedicated environmental staff often needed
Waste Minimization Strategies:
Source Reduction:
Process improvements reducing waste generation
Material substitution (less hazardous alternatives)
Better inventory management (reduce expiration waste)
Equipment maintenance (prevent leaks and spills)
Employee training (proper use reduces waste)
Recycling:
Used oil recycling (doesn't count as hazardous waste generation)
Solvent recycling through distillation
Metal recycling
Antifreeze recycling
Battery recycling through universal waste
Waste Segregation:
Separate recyclable from disposable wastes
Don't contaminate recyclable streams
Keep different waste types separate for optimal recycling
Process Changes:
Closed-loop systems
Counter-current rinsing reducing wastewater
Improved application efficiency (painting, coating)
Better material handling reducing spills
Timing Management:
Spread large cleanouts across multiple months
Schedule equipment maintenance to distribute waste generation
Plan facility improvements considering waste generation timing
Optimizing Your SQG Waste Program
Container Management:
Right-Size Containers:
Don't use 55-gallon drums for wastes generated slowly (small containers prevent exceeding accumulation times)
Large containers for high-volume waste streams
Standardize where possible (simplifies training and procurement)
Color-Coding:
Different colors for different waste types
Visual identification reduces mixing errors
Red for flammable, yellow for corrosive, etc.
Labeling System:
Pre-printed labels save time
Include all required information (Hazardous Waste, contents, accumulation date)
Laminated labels resist weather and chemicals
Use permanent markers
Accumulation Date Tracking:
Implement System Preventing Time Limit Violations:
Manual Tracking:
Spreadsheet or logbook listing each container
Accumulation start date
Projected pickup date
Actual pickup date
Responsible person checks monthly
Software Solutions:
Environmental compliance software
Automated alerts before deadlines
Digital recordkeeping
Integration with manifest system
Visual Management:
Calendar board showing container accumulation dates
Color-coded markers for containers approaching limits
Weekly review meetings
Conservative Scheduling:
Schedule pickups 2-4 weeks before accumulation deadline
Allows flexibility for scheduling conflicts, holidays, weather
Prevents last-minute emergencies
180 vs. 270 Day Determination:
Measure distance to permitted TSDF
Document measurement method (GPS, mapping software, mileage)
Retain documentation for inspections
Reassess if TSDF options change
Manifesting Best Practices
Streamline Manifest Completion:
Pre-Fill Information:
Generator name, address, EPA ID number
Common waste descriptions
Usual transporter and TSDF information
E-Manifest Benefits:
Faster completion
Automatic copy distribution
Better recordkeeping
Searchable archive
Worth the fee for most SQGs
Review Before Signing:
Verify waste description accuracy
Confirm quantities
Check EPA ID numbers correct
Ensure all required fields complete
Generator Certification: When signing manifest, you certify:
Waste properly classified, packaged, marked, labeled
Shipment complies with regulations
Waste minimization program in place (LQG requirement, good practice for SQGs)
Tracking Return Copies:
Create tickler file for outstanding manifests
Follow up at 45-50 days if not received
Exception reporting at 75 days
Maintain contact log
Training Program Development
Create Effective SQG Training:
Initial Training Module (2-3 hours):
Company hazardous waste policy
Waste identification for facility-specific materials
Container selection and labeling procedures
Accumulation area locations and rules
Accumulation time limits
Spill response procedures
Emergency contacts
Personal protective equipment
Q&A and hands-on practice
Annual Refresher (1 hour):
Regulatory updates
Facility changes
Review of procedures
Common mistakes review
New waste streams
Incident reviews (if any)
Training Documentation Template:
Employee Training Record
Employee Name: _________________
Position: _________________
Training Date: _________________
Training Topics:
☐ Waste Identification
☐ Container Management
☐ Labeling Requirements
☐ Accumulation Time Limits
☐ Spill Response
☐ Emergency Procedures
☐ PPE Requirements
☐ Manifesting (if applicable to position)
Instructor: _________________
Employee Signature: _________________
Supervisor Signature: _________________
Training Methods:
In-person group sessions (most effective)
Online modules (good for refreshers)
On-the-job training with mentoring
Videos or presentations
Combination approach
Common SQG Violations and How to Avoid Them
EPA enforcement actions reveal common compliance failures.
Violation #1: Exceeding Accumulation Time Limits
The Problem: Most common SQG violation. Containers exceed 180/270-day limits due to:
Forgetting containers in storage areas
Poor tracking systems
Assuming more time allowed
Intentional delay to reduce service frequency
Consequences:
Operating storage facility without permit
Penalties $37,500+ per day per violation
Immediate corrective action required
Increased regulatory scrutiny
Prevention:
Implement robust tracking system
Mark accumulation dates clearly and legibly
Regular reviews (weekly or monthly)
Schedule pickups conservatively (2-4 weeks before deadline)
Train staff on importance
Violation #2: Improper or Missing Labels
The Problem: Containers missing required information:
No "Hazardous Waste" label
Missing or illegible accumulation date
Vague waste description
Labels weathered or damaged
Consequences:
Violation of container labeling requirements
Penalties per container
Safety hazards
Prevention:
Use durable, weather-resistant labels
Pre-printed labels with required fields
Regular label inspections and replacement
Training on proper labeling
Laminated labels for outdoor storage
Violation #3: Operating Without EPA ID Number
The Problem: Shipping hazardous waste without obtaining EPA ID number or using incorrect number.
Consequences:
Serious violation - generator not in system
Manifests invalid
Waste tracking broken
Significant penalties
Prevention:
Obtain EPA ID immediately when becoming SQG
Verify number on all manifests
Keep documentation of EPA ID assignment
Update if facility moves or changes ownership
Violation #4: Failure to Manifest Waste
The Problem: Shipping hazardous waste without proper manifest or incomplete manifest.
Consequences:
Violation of manifest requirements
No documentation waste properly managed
Penalties per shipment
Generator liability if waste mismanaged
Prevention:
Use manifest for every shipment (no exceptions)
Complete all required fields
Retain copies per regulations
Verify transporter and TSDF have valid EPA IDs
Use reputable disposal companies ensuring proper manifesting
Violation #5: Inadequate Personnel Training
The Problem: No training records or insufficient training for employees handling hazardous waste.
Consequences:
Violation of training requirements
Employees make mistakes leading to other violations
Safety incidents
Penalties
Prevention:
Implement formal training program
Document all training thoroughly
Initial training for new employees
Annual refresher training
Maintain training records minimum 3 years
Keep records readily available
Violation #6: Improper Storage
The Problem:
Containers in poor condition
No secondary containment
Incompatible wastes stored together
Containers left open
Consequences:
Violation of storage requirements
Spills and releases
Safety hazards
Penalties
Prevention:
Use containers in good condition
Inspect containers regularly
Provide adequate secondary containment
Separate incompatible wastes
Keep containers closed
Protect from weather
Train staff on proper storage
Violation #7: Failure to Track Manifests
The Problem: Not following up on manifests or filing exception reports when required.
Consequences:
Violation of manifest tracking requirements
Unknown disposition of waste
Potential waste mismanagement
Prevention:
Implement manifest tracking system
Follow up if copy not received within 60 days
File exception report at 75 days
Maintain organized manifest files
Document all follow-up efforts
Frequently Asked Questions About SQGs
Can we store waste longer than 180/270 days if we're waiting for a better disposal price?
No. Accumulation time limits are absolute. You cannot exceed 180 days (or 270 if >200 miles) regardless of reason. Intentionally delaying disposal to reduce costs or waiting for "better pricing" violates regulations.
If you exceed accumulation limits, you're operating a storage facility without a permit - serious violation with significant penalties.
Strategy: Work with your disposal company to negotiate volume pricing or scheduled pickups rather than trying to extend accumulation times.
What if we exceed 1,000 kg in one month but normally generate less?
You immediately become an LQG for that month and must comply with all LQG requirements:
90-day accumulation limit (effective immediately for containers started in that month)
Comprehensive training (should already be in place)
Written contingency plan (should develop immediately)
All other LQG requirements
You cannot:
Ignore the exceedance hoping regulators won't notice
Continue operating as SQG that month
You should:
Begin LQG compliance immediately
Document the exceedance
Evaluate whether you'll regularly exceed (if so, implement full LQG program)
If one-time event, return to SQG status following month (if generation drops below 1,000 kg)
Prevention:
Track waste generation closely
Plan large cleanouts across multiple months
Implement waste minimization before threshold approached
Do we need a written contingency plan as an SQG?
No - formal written contingency plan is not federally required for SQGs. This is an LQG requirement.
However, SQGs must:
Have basic emergency procedures
Designate emergency coordinator
Maintain emergency equipment
Have emergency contact numbers
Best Practice: Many SQGs develop written emergency procedures even though not required:
Helps organize response
Provides training documentation
Protects in emergencies
Prepares for potential future LQG status
Some states may require
Can we use the same EPA ID number for multiple facilities?
No. Each physical location where hazardous waste is generated needs its own EPA ID number.
Example: Company with manufacturing plant in Ohio, warehouse in Pennsylvania, and satellite office in Michigan needs three separate EPA ID numbers.
Reason: EPA tracks waste generation by facility location. Using wrong EPA ID makes tracking impossible and violates regulations.
Exception: Mobile or temporary facilities may use different rules - contact EPA or state agency.
What's the penalty for an SQG violation?
Federal civil penalties under RCRA can be up to $71,433 per day per violation (adjusted annually for inflation).
Typical penalties:
First-time, minor violation with quick correction: Warning letter or small penalty ($1,000-$10,000)
Accumulation time violation: $10,000-$50,000
Multiple or serious violations: $50,000-$500,000+
Knowing violations: Criminal penalties including imprisonment
State penalties vary but often similar ranges.
Factors affecting penalties:
Violation severity
Environmental harm
Compliance history
Good faith efforts to comply
Economic benefit gained from non-compliance
Corrective action taken
Best approach: Proactive compliance preventing violations far cheaper than penalties, legal costs, and regulatory scrutiny.
Is training required for all employees or just those handling waste?
Federal SQG training requirement applies to:
Employees whose job responsibilities involve hazardous waste management
Personnel handling containers
Staff in accumulation areas
Waste coordinators
Anyone making waste determinations
Not required for:
Administrative staff with no waste contact
Sales personnel
Employees in areas isolated from hazardous waste operations
Best Practice: Provide basic awareness training for all employees:
What is hazardous waste
Where accumulation areas located
Who to contact with questions
Basic safety information
Then comprehensive training for employees directly involved with hazardous waste.
Can we treat hazardous waste on-site?
Generally requires permit. Treatment of hazardous waste typically requires RCRA permit as treatment, storage, and disposal facility (TSDF).
Exceptions:
Elementary neutralization (pH adjustment of corrosive waste) in certain situations
Totally enclosed treatment units
Wastewater treatment units meeting specific criteria
Some recycling activities
Most SQGs:
Don't treat waste on-site
Send waste to permitted TSDFs for treatment
Focus on waste minimization rather than on-site treatment
If considering on-site treatment: Consult with environmental professionals and regulators - permit requirements are complex and expensive.
What if our disposal company doesn't use manifests?
Red flag - do not use this company.
All SQG hazardous waste shipments must be manifested. If disposal company says manifests aren't needed or doesn't provide them, they're:
Operating illegally
Not a permitted facility
Likely dumping waste improperly
You remain liable even if disposal company mismanages waste. Using unpermitted haulers or facilities creates enormous liability.
Always:
Verify disposal company has valid EPA ID number
Ensure they provide proper manifests
Request proof of permits
Check references
Get certificates of disposal
State-Specific SQG Requirements
States can impose requirements beyond federal SQG rules.
States with Enhanced SQG Requirements
Tiered fees based on generation (even SQGs pay fees)
Additional notification requirements
Site identification numbers in addition to EPA ID
Electronic manifest requirements in some cases
Stricter inspector access rules
Annual generator fees
No 270-day extension (strict 180-day limit for all SQGs)
Additional training requirements in some situations
Site-specific requirements in certain jurisdictions
Hazardous waste facility fees
Enhanced manifest tracking
Additional contingency planning in some cases
Strict accumulation area requirements
Annual reporting for some SQGs
Fee requirements
Strict manifest and tracking rules
Generator fee program
Electronic manifest requirements
"Dangerous waste" regulations (state equivalent of RCRA)
Enhanced accumulation area standards
Fee program
Checking Your State Requirements
Visit state environmental agency website
Call state hazardous waste program
Consult with qualified environmental professional (we can help)
Review state-specific guidance documents
Check local (city/county) requirements - some jurisdictions add local rules
Transitioning Between Generator Categories
From VSQG to SQG
When it happens: First month you generate ≥100 kg hazardous waste
Immediate actions:
Obtain EPA ID number (before first waste shipment as SQG)
Implement manifest system
Mark accumulation start dates on all containers
Begin accumulation time tracking
Develop basic emergency procedures
Implement personnel training program
Establish recordkeeping system
Timeline:
Stop operating as VSQG immediately upon exceeding threshold
SQG requirements effective same month as exceedance
Common mistake: "Grace period" myth - none exists
From SQG to LQG
When it happens: First month you generate ≥1,000 kg hazardous waste OR >1 kg acutely hazardous waste
Immediate actions:
Reduce accumulation time limit to 90 days (for new containers)
Develop written contingency plan
Implement comprehensive annual training program
Establish weekly documented inspection program
Develop preparedness and prevention plan
Plan for biennial reporting (March 1 of even years)
Evaluate need for dedicated environmental staff
Returning to SQG: If generation drops below 1,000 kg in future months, can return to SQG status, but must maintain LQG compliance for all waste accumulated during LQG month(s).
Getting Professional Help with SQG Compliance
When to Hire Environmental Professionals
Consider professional assistance if:
Transitioning from VSQG to SQG
Approaching LQG threshold
Facing regulatory inspection
Receiving violation notice
Implementing new processes generating waste
Unsure about waste characterization
Need training program development
Want compliance audit
Expanding operations
Our SQG Services
At Hazardous Waste Disposal, we provide comprehensive SQG compliance support:
Waste Management Services:
Container provision (all sizes, proper DOT specifications)
Scheduled pickup service (within accumulation time limits)
Manifesting and documentation
Treatment and disposal at permitted facilities
Certificates of destruction/disposal
Electronic manifest (e-Manifest) services
Compliance Support:
EPA ID number application assistance
Waste characterization and classification
Accumulation time tracking systems
Training program development and delivery
Emergency procedure development
Manifest training and assistance
Regulatory compliance audits
State-specific requirement guidance
Cost Optimization:
Waste minimization assessments
Process improvements reducing generation
Recycling program development
Service frequency optimization
Helping stay below LQG threshold
Expert Guidance:
Regulatory interpretation
Violation response support
Inspection preparation
Best practice recommendations
Industry-specific expertise
Conclusion: SQG Compliance Simplified
Being a Small Quantity Generator places you in the middle of RCRA's regulatory spectrum. You have more requirements than VSQGs but more flexibility than LQGs.
Your Essential SQG Responsibilities:
Get EPA ID number - Required before first shipment
Track accumulation times - Never exceed 180/270 days
Manifest all shipments - Document every waste pickup
Train personnel - All staff handling hazardous waste
Store properly - Good containers, labels, secondary containment
Use permitted facilities - Only legitimate TSDFs
Keep records - Manifests, training, documentation (3+ years)
Have emergency procedures - Basic plans and equipment
Benefits of Proper SQG Compliance:
Legal Protection:
Avoid penalties and fines ($10,000-$100,000+ for violations)
Reduce liability exposure
Demonstrate environmental responsibility
Prevent enforcement actions
Operational Benefits:
Organized waste management
Reduced operational disruptions
Better employee safety
Potential cost savings through waste minimization
Strategic Advantages:
Positive regulatory relationship
Customer confidence (for B2B businesses)
Insurance benefits
Corporate sustainability goals
Next Steps:
If you're an SQG or becoming one:
Assess current compliance status - Are you meeting all requirements?
Implement tracking systems - Especially accumulation dates
Develop training program - Document everything
Partner with reputable disposal company - Critical for compliance
Consider professional audit - Identify and fix gaps before inspection
Contact Us for SQG Support
Call (800) 582-4833 or email info@hazardouswastedisposal.com
We specialize in helping Small Quantity Generators across all industries manage hazardous waste compliantly and cost-effectively.
Our SQG services include:
Complete waste management programs
Manifesting and documentation
Personnel training
Compliance support and auditing
Accumulation time tracking assistance
Emergency response
All waste types and industries
Serving SQGs nationwide, since 1992
Let our expertise simplify your SQG compliance so you can focus on running your business. Contact us today for a free consultation and quote.
This guide is for informational purposes. Regulations change and vary by location. Consult with qualified environmental professionals and your state agency for specific compliance requirements. Updated January 2026.