The Complete Guide to Very Small Quantity Generators (VSQGs): Everything Your Business Needs to Know
The Complete Guide to Very Small Quantity Generators (VSQGs): Everything Your Business Needs to Know
Last Updated: January 2026
If your business generates hazardous waste, understanding your regulatory classification is critical for compliance and cost management. Most small businesses in America fall into the Very Small Quantity Generator (VSQG) category, which comes with minimal federal regulatory requirements but important responsibilities that can't be ignored.
This comprehensive guide covers everything you need to know about VSQG status: what it means, how to qualify, what regulations apply, best practices for compliance, and how to avoid common pitfalls that could lead to violations and penalties.
What is a Very Small Quantity Generator (VSQG)?
A Very Small Quantity Generator is the EPA's classification for facilities that generate relatively small amounts of hazardous waste. Under the Resource Conservation and Recovery Act (RCRA), VSQGs are the lowest regulatory tier for hazardous waste generators, with streamlined requirements compared to larger generators.
VSQG Definition and Thresholds
Your facility qualifies as a VSQG if you generate:
Less than 100 kilograms (220 pounds) per month of hazardous waste
AND
Less than 1 kilogram (2.2 pounds) per month of acutely hazardous waste (P-listed waste)
To put this in perspective:
100 kg is roughly one half-full 55-gallon drum of hazardous waste per month
Most small businesses easily stay under this threshold
A single gallon of solvent weighs approximately 6-8 pounds, so 100 kg is about 25-35 gallons
Why the VSQG Category Exists
The EPA created the VSQG category (formerly called "Conditionally Exempt Small Quantity Generators" or CESQGs before 2016) recognizing that:
Small businesses need regulatory relief - Applying full hazardous waste regulations to every auto repair shop, dry cleaner, or dental office would be impractical and economically burdensome
Small volumes pose lower risk - Facilities generating minimal hazardous waste present less environmental and public health risk than large industrial operations
Simplified compliance encourages proper disposal - If regulations are too complex, small businesses might be tempted to dispose improperly. Streamlined rules promote compliance.
Economic feasibility - The cost of full regulatory compliance (permits, extensive training, detailed manifesting) would be prohibitive for many small businesses
Who Typically Qualifies as a VSQG?
Thousands of business types across virtually every industry can be VSQGs. Here are common examples:
Auto-Related Businesses
Auto Repair Shops and Mechanics:
Used motor oil and transmission fluid
Brake fluid and power steering fluid
Antifreeze and coolant
Spent solvents and degreasers
Oil filters and contaminated rags
Parts washer fluids
Auto Body Shops:
Paints and primers
Paint thinners and solvents
Body filler and resin waste
Spray gun cleaning waste
Sandblasting dust (if hazardous)
Car Washes:
Cleaning chemical waste
Wastewater (if hazardous characteristics)
Healthcare and Medical
Physician Offices and Clinics:
Small amounts of pharmaceutical waste
Laboratory chemicals (if on-site lab)
X-ray chemistry (declining with digital)
Cleaning and disinfecting chemicals
Mercury thermometers and devices (being phased out)
Dental Offices:
Amalgam waste (mercury-containing)
X-ray fixer and developer (if still using film)
Disinfectants and sterilants
Lead foil from x-ray packets
Veterinary Clinics:
Pharmaceutical waste (similar to medical)
Anesthetic waste
Cleaning chemicals
Laboratory chemicals
Note: Medical waste (infectious waste, sharps) is regulated separately from hazardous waste. See our Biomedical Waste Disposal page for medical waste guidance.
Service and Maintenance Businesses
Perchloroethylene (perc) - if still used
Petroleum solvents
Spent filters
Distillation residues (still bottoms)
Printing inks
Fountain solutions
Press wash solvents
Plate developing chemicals
Contaminated rags
Pesticide containers
Recalled or banned pesticides
Mixed pesticides not used
Contaminated equipment cleaning waste
Photo processing chemistry (if not digital)
Fixer with silver content
Developer solutions
Retail and Commercial
Hardware Stores:
Damaged paint inventory
Pesticide returns or damage
Aerosol products
Automotive fluids
Cleaning products
Small Retail Pharmacies:
Expired or damaged pharmaceuticals
Controlled substances (DEA regulations apply)
Recalled medications
Gas Stations and Convenience Stores:
Waste fuel
Oil and automotive fluids (if offering service)
Cleaning chemicals
Manufacturing and Industrial (Small Scale)
Small Machine Shops:
Cutting fluids and coolants
Parts washer solvents
Hydraulic fluids
Contaminated rags and absorbents
Metal fines (if hazardous)
Small Fabrication Shops:
Welding waste
Painting and coating waste
Solvents and degreasers
Cutting oils
Wood Working Shops:
Stains and finishes
Paint strippers
Solvents and thinners
Adhesives
Electronics Repair:
Solder waste
Flux residues
Cleaning solvents
Circuit board cleaning waste
Laboratories and Research
University Teaching Laboratories:
Expired or surplus chemicals
Laboratory reagent waste
Small-scale experiment waste
Broken thermometers (mercury)
Quality Control Laboratories:
Testing reagents
Standards and calibration solutions
Sample extraction solvents
Environmental Testing Labs:
Sample preservation acids
Extraction solvents
Quality control materials
Other Common VSQGs
Schools and Educational Institutions:
Science laboratory chemicals
Art department solvents and paints
Maintenance department waste (cleaners, paints)
Marinas and Boat Maintenance:
Bottom paint (often contains heavy metals)
Solvents and cleaners
Used oil and antifreeze
Paint strippers
Furniture Refinishing:
Paint strippers (often methylene chloride)
Stains and varnishes
Solvents and thinners
Janitorial Service Companies:
Cleaning chemical waste
Floor stripper and polish waste
VSQG Requirements: What You Must Do
While VSQGs have minimal federal requirements compared to larger generators, there are still important compliance obligations.
1. Identify Your Hazardous Waste
You must determine if your waste is hazardous.
Waste is hazardous if it:
Exhibits a hazardous characteristic:
Ignitability (D001): Flash point below 140°F - solvents, paints, alcohols
Corrosivity (D002): pH ≤2 or ≥12.5 - acids, bases, rust removers, drain cleaners
Reactivity (D003): Unstable, water-reactive, or explosive - rare in VSQGs
Toxicity (D004-D043): Contains specific toxic elements or compounds above regulatory levels
OR is specifically listed as hazardous:
F-listed wastes: Spent solvents and specific industrial wastes
K-listed wastes: Industry-specific wastes (rarely applies to VSQGs)
P-listed wastes: Acutely hazardous discarded commercial chemical products
U-listed wastes: Toxic discarded commercial chemical products
How to Determine Hazardous Status:
Most VSQGs use "generator knowledge" - understanding your processes and materials to classify waste:
Check Safety Data Sheets (SDS) for hazardous properties
Identify solvents, paints, pesticides as likely hazardous
Note cleaning chemicals with extreme pH
Review product labels for hazard warnings
Laboratory testing is expensive and rarely needed for VSQGs with straightforward waste streams. If you're unsure, contact a hazardous waste professional (like us) for guidance.
2. Never Exceed VSQG Thresholds
Monitor your waste generation to stay under limits:
Less than 100 kg (220 lbs) per month of hazardous waste
Less than 1 kg (2.2 lbs) per month of acutely hazardous (P-listed) waste
Less than 1,000 kg (2,200 lbs) accumulated on-site at any time
If you exceed these thresholds even once, you immediately jump to Small Quantity Generator (SQG) status with significantly more regulatory requirements including:
EPA ID number required
Manifesting all shipments
180-day (or 270-day) accumulation time limits
Personnel training requirements
Contingency planning
More extensive recordkeeping
Waste Minimization Strategies: To stay within VSQG limits:
Buy only what you need (prevent excess becoming waste)
Use materials completely before disposing
Rotate inventory to prevent expiration
Substitute less hazardous alternatives where possible
Recycle used oil and other recyclables (doesn't count toward generation limits)
3. Store Waste Properly
VSQGs must ensure basic safe storage:
Container Requirements:
Use containers in good condition (no rust, leaks, damage)
Containers must be compatible with waste (no plastic for solvents that dissolve plastic)
Keep containers closed except when adding or removing waste
Label containers clearly with contents
Storage Location:
Away from incompatible materials (don't store acids next to bases)
Protected from weather if outdoors
Away from drains and water bodies
Secure area preventing unauthorized access
Secondary containment for liquids (recommended, not always required for VSQGs)
Don't accumulate more than 1,000 kg (2,200 lbs) on-site at any time - this would move you to SQG status even if monthly generation stays low.
4. Send Waste to Appropriate Facility
This is your most critical responsibility as a VSQG.
You must ensure your hazardous waste goes to one of the following:
Permitted hazardous waste treatment, storage, or disposal facility (TSDF)
Recycling facility (for recyclable wastes like used oil, solvents, metals)
Universal waste handler or destination facility (for batteries, lamps, electronics, mercury devices)
How to ensure proper disposal:
Use a reputable waste disposal company (like Hazardous Waste Disposal) with proper permits and certifications
Request proof of disposal - legitimate companies provide certificates of destruction or disposal documenting where waste was sent
Never:
Pour hazardous waste down drains
Put hazardous waste in dumpsters or regular trash
Burn hazardous waste in open fires or non-permitted incinerators
Bury hazardous waste
Give waste to unlicensed or questionable haulers
Abandon containers on property
Avoid illegal dumping schemes - if disposal seems too cheap or "too good to be true," it probably violates regulations. You remain liable even after waste leaves your facility if sent to unlicensed dumper.
5. Optional but Recommended: Get an EPA ID Number
VSQGs are not required to obtain EPA ID numbers, but we strongly recommend it:
Benefits of getting EPA ID number as VSQG:
Provides clear documentation of your regulatory status
Allows manifest use (provides better documentation trail)
Protects you if waste is mismanaged downstream
Required if you ever exceed VSQG limits even once
Some states require EPA ID numbers even for VSQGs
Some disposal companies prefer or require it
How to obtain EPA ID number:
Contact your state environmental agency
Complete notification form (varies by state)
Online systems available in many states
Usually free or minimal cost
Takes 2-4 weeks typically
6. State-Specific Requirements
States can impose requirements beyond federal VSQG rules.
Some states require VSQGs to:
Obtain EPA ID numbers (California, for example)
File annual reports
Pay fees
Follow specific storage, labeling, or manifest requirements
Register with state agency
Check your state requirements - we can help determine what applies in your location.
VSQG vs. SQG vs. LQG: Understanding the Differences
Understanding how VSQG compares to other generator categories helps you appreciate the streamlined requirements.
Comparison Table
Requirement VSQG SQG LQG Monthly Generation <100 kg hazardous waste 100-1,000 kg ≥1,000 kg Acutely Hazardous <1 kg per month <1 kg per month >1 kg per month Maximum On-Site <1,000 kg <6,000 kg No limit (with permit) EPA ID Number Not required Required Required Manifest Required No Yes Yes Accumulation Time No federal limit 180 days (or 270) 90 days Personnel Training Not required Basic training Comprehensive annual Contingency Plan Not required Basic procedures Detailed written plan Inspections Not required Weekly recommended Weekly required Biennial Report No No Yes Closure Plan No No Yes (if required)
Key Takeaway: VSQG status provides enormous regulatory relief compared to SQG and LQG categories. Staying under the 100 kg/month threshold saves significant compliance costs and administrative burden.
Common VSQG Mistakes to Avoid
Even with minimal requirements, VSQGs make mistakes that can lead to violations.
Mistake #1: Assuming All Waste is Non-Hazardous
The Problem: Many VSQGs assume their waste isn't hazardous and dispose in regular trash or down drains without checking.
The Reality: Common business wastes ARE often hazardous:
Auto shop solvents and degreasers - hazardous
Dry cleaning fluids - hazardous
Paint shop wastes - hazardous
Dental amalgam - hazardous
Pesticides - hazardous
The Solution: Review materials you use, check SDS sheets, and properly classify waste. When in doubt, treat as hazardous until proven otherwise.
Mistake #2: Improper Disposal Methods
The Problem: Pouring solvents down drains, throwing paint cans in dumpsters, burning waste, or using unlicensed haulers.
The Reality: These practices violate regulations and create liability. You're responsible for waste even after it leaves your site ("cradle to grave" responsibility).
The Solution: Use legitimate hazardous waste disposal companies with proper permits. Request certificates of disposal. Never use illegal disposal methods.
Mistake #3: Mixing Incompatible Wastes
The Problem: Combining acids and bases, or mixing different solvents to "save money on disposal."
The Reality: Mixing can create:
Dangerous chemical reactions (heat, toxic gases, explosions)
Safety hazards for workers and haulers
Increased disposal costs (mixed waste harder to recycle or treat)
Regulatory violations
The Solution: Keep waste streams segregated:
Acids separate from bases
Solvents separate from water-based wastes
Oil separate from solvents
Follow waste disposal company guidance on segregation
Mistake #4: Poor Container Management
The Problem: Using damaged containers, leaving containers open, improper labeling, storing near incompatibles.
The Reality: Creates safety hazards, spills, fires, and regulatory violations.
The Solution:
Inspect containers before use
Keep containers closed
Label clearly with contents
Store properly (away from incompatibles, drains, weather)
Use compatible containers (right material for waste type)
Mistake #5: Exceeding VSQG Limits Without Realizing It
The Problem: Not tracking waste generation, then exceeding 100 kg threshold and becoming SQG without knowing it.
The Reality: Once you exceed limits even in a single month, you immediately have SQG requirements (EPA ID, manifests, accumulation limits, training) whether you know it or not. Ignorance is not a defense.
The Solution:
Estimate waste generation monthly
If approaching 100 kg, track more carefully
Implement waste minimization
If you'll regularly exceed, prepare for SQG compliance
Keep records of disposal to demonstrate VSQG status
Mistake #6: No Documentation
The Problem: No records of what waste was disposed, when, where, or by whom.
The Reality: If regulators inspect or if waste is found dumped illegally, you have no proof of proper disposal. The burden is on you to demonstrate compliance.
The Solution: Even though VSQGs aren't required to manifest, maintain:
Disposal receipts from waste company
Certificates of disposal or destruction
Basic records of waste types and quantities
Contact information for disposal company
Proof of proper disposal protecting you from liability
Mistake #7: Ignoring State Requirements
The Problem: Assuming federal VSQG rules are the only requirements.
The Reality: States can be more stringent. California, New York, New Jersey, and others have additional VSQG requirements.
The Solution: Check state environmental agency website or contact us to understand state-specific rules in your location.
Best Practices for VSQG Compliance
Going beyond minimum requirements protects your business.
Implement a Simple Waste Management Program
Even though formal programs aren't required for VSQGs, basic organization helps:
1. Designate a Waste Coordinator
One person responsible for hazardous waste management
Ensures consistency and accountability
Point of contact for waste disposal company
2. Create Basic Procedures
Written steps for identifying hazardous waste
Container labeling process
Storage location and practices
Who to call for pickup
Emergency spill response
3. Train Employees
Not federally required for VSQGs but smart practice
Quick orientation on what's hazardous waste
Proper container use and labeling
Who to contact with questions
Spill response basics
4. Keep Simple Records
Waste pickup dates and quantities
Disposal company receipts
Certificates of disposal
Annual waste generation estimates
Store records 3-5 years
Use Legitimate Disposal Companies
Red flags indicating potentially illegal hauler:
Prices far below competitors ("too good to be true")
No business address or operating location
Can't provide proof of permits or licenses
Reluctant to provide certificates of disposal
Pressures you for immediate decision
Cash-only payment
No insurance or bonding
Poor online presence or reviews
What legitimate companies provide:
Clear pricing and contracts
Proper permits and licenses
Certificates of disposal
Professional equipment and uniforms
Insurance documentation
Established business presence
References or customer testimonials
Transparent processes
Consider Universal Waste Options
Universal waste regulations provide streamlined handling for common waste types:
Universal Waste Categories:
Batteries (lead-acid, rechargeable, button cells)
Lamps (fluorescent, CFLs, HID, mercury vapor)
Mercury-containing equipment (thermostats, switches)
Electronic waste (computers, monitors, devices)
Some pesticides (in certain states)
Benefits of Universal Waste:
Simpler labeling (don't need "Hazardous Waste" label)
Longer storage time (1 year vs. indeterminate for VSQGs)
Often easier recycling options
Lower disposal costs in some cases
If your VSQG waste includes batteries, lamps, or electronics, universal waste rules may be advantageous.
Implement Waste Minimization
Reducing waste generation saves money and reduces regulatory risk:
Source Reduction:
Buy only what you need
Use materials completely
Substitute less hazardous alternatives (water-based instead of solvent-based)
Maintain equipment preventing leaks and spills
Improve processes reducing waste generation
Recycling:
Used oil can be recycled (doesn't count as hazardous waste generation)
Solvent recycling (distillation)
Metal recycling
Battery recycling
Antifreeze recycling
Inventory Management:
First-in, first-out rotation
Monitor expiration dates
Order smaller quantities more frequently
Share chemicals with other departments or businesses
Maintain Spill Response Capability
Even small generators should be prepared for spills:
Basic Spill Kit Contents:
Absorbent pads and socks
Absorbent granules or clay
Plastic bags for cleanup materials
Gloves and eye protection
Disposal container
Spill response instructions
Spill Response Steps:
Ensure personal safety
Stop source if safe to do so
Contain spill preventing spread
Ventilate area if indoors
Use appropriate PPE
Absorb liquid with absorbents
Place contaminated materials in disposal container
Decontaminate affected area
Dispose of cleanup materials as hazardous waste
Document incident
Plan for Business Changes
Monitor waste generation if business expands:
Increased production may increase waste
New processes may create new waste streams
Seasonal variations may affect generation
Track monthly to ensure staying under VSQG limits
Prepare for SQG transition if needed:
If expanding will exceed 100 kg/month, plan ahead
Obtain EPA ID number before exceeding limits
Implement training program
Develop basic contingency plan
Understand manifest system
Adjust waste storage and labeling
VSQG Disposal: How It Works
Understanding the disposal process helps VSQGs work effectively with waste companies.
Step 1: Initial Contact and Assessment
When you call a disposal company:
Describe your business type
List waste types and estimated quantities
Indicate service frequency needed (one-time, quarterly, annual)
Mention any special concerns
Disposal company will:
Confirm VSQG status
Recommend container sizes and types
Provide pricing quote
Schedule service date
Answer questions about regulations
Step 2: Container Provision (If Needed)
Many disposal companies provide containers:
5-gallon buckets for small quantities
30-gallon or 55-gallon drums for larger amounts
Specialized containers (battery buckets, lamp boxes, sharps containers)
Proper labels and markings
Or you provide your own:
DOT-approved containers if transporting
Compatible with waste type
Good condition, no damage
Properly labeled
Step 3: Waste Accumulation
You accumulate waste over time:
Place waste in designated containers
Keep containers closed when not adding waste
Store in appropriate location
Monitor quantity to stay under 1,000 kg on-site limit
Label containers with contents
When container is full or ready for pickup:
Contact disposal company to schedule
No strict time limit for VSQGs (unlike SQGs with 180/270-day limits)
Practical limits: odors, safety, space constraints
Step 4: Pickup Service
On scheduled date:
Disposal company arrives with proper vehicle
Driver reviews containers
May ask questions about waste contents
Loads containers onto truck
Provides receipt or paperwork
VSQGs typically don't use manifests (not required), but legitimate companies still document:
What was picked up
Date and location
Where waste is being taken
Quantity and description
Step 5: Treatment and Disposal
Waste is transported to permitted facility for:
Recycling: Used oil, solvents, metals, batteries, antifreeze
Incineration: Paints, some solvents, pesticides
Fuel blending: Some solvents used as alternative fuel
Chemical treatment: Neutralization, stabilization
Secure landfill: After treatment meeting land disposal restrictions
You receive certificate of disposal:
Proof waste was properly managed
Documents disposal date and method
Final destination facility
Retain for your records (3-5 years recommended)
Step 6: Payment
Billing options vary:
Pay per pickup (most common for VSQGs)
Annual contracts (if regular service)
Flat rate per container
Per-pound pricing
Include container costs or separate
Typical VSQG disposal costs:
Small pickup (one 5-gallon pail): $150-$400
Medium pickup (30-gallon drum): $300-$800
Larger pickup (55-gallon drum): $400-$1,200
Depends on waste type, quantity, location, service
Frequently Asked Questions About VSQGs
Do VSQGs need EPA ID numbers?
Federal requirement: No, VSQGs are not federally required to obtain EPA ID numbers.
State requirements: Some states require EPA ID numbers even for VSQGs (California, for example). Check your state regulations.
Best practice recommendation: We recommend getting an EPA ID number even if not required because it:
Provides documentation of regulatory status
Allows manifest use for better documentation
Required if you ever exceed VSQG limits even once
Protects you legally
Some disposal companies prefer or require it
How to get one: Contact your state environmental agency or use their online system. Usually free or low cost.
Can VSQGs dispose of hazardous waste in regular trash?
No, absolutely not. Even though VSQGs have minimal regulations, you cannot:
Put hazardous waste in dumpsters or regular trash
Pour hazardous waste down drains or sewers
Burn hazardous waste in open fires
Bury hazardous waste
Dump hazardous waste on land or in waterways
These practices violate environmental laws, create public health hazards, and subject you to penalties and liability.
You must send hazardous waste to permitted disposal facilities through legitimate disposal companies.
How long can VSQGs store hazardous waste?
Federal RCRA: No specific time limit for VSQGs. Unlike SQGs (180/270 days) and LQGs (90 days), VSQGs don't have federal accumulation time limits.
Practical limits:
Cannot accumulate more than 1,000 kg (2,200 lbs) on-site
Must maintain containers in good condition
Prevent leaks, spills, odors
Local fire codes may limit quantities
Nuisance regulations (odors, aesthetics)
State regulations: Some states impose time limits on VSQGs. Check your state requirements.
Best practice: Don't accumulate indefinitely. Schedule disposal quarterly or annually even without time limits.
What if we exceed VSQG limits for one month?
You immediately become a Small Quantity Generator (SQG) subject to more requirements:
Must obtain EPA ID number before first shipment as SQG
Must manifest all waste shipments
180-day accumulation limit (or 270 days if >200 miles to facility)
Basic personnel training required
Emergency response procedures needed
More extensive recordkeeping
Exceeding even once changes status - you don't get a warning or grace period. Plan ahead if you know you'll exceed limits (equipment cleaning, facility renovation, process changes generating extra waste).
Returning to VSQG status: You can revert to VSQG in subsequent months if generation drops below limits, but you must still comply with SQG rules for shipments made while you were SQG.
Do we need to manifest VSQG waste?
Not required federally. VSQGs are exempt from manifest requirements.
However:
Some states require manifests even for VSQGs
Some disposal companies use manifests or similar tracking documents regardless of generator status
Using manifests is best practice providing documentation trail
We recommend some form of documentation even if not manifesting:
Disposal receipts
Certificates of disposal
Pickup records
Waste descriptions and quantities
This protects you if waste is later found improperly disposed.
Can VSQGs recycle used oil?
Yes, and you should! Used oil managed under used oil regulations (40 CFR 279) doesn't count toward your hazardous waste generation limits.
Benefits of used oil recycling:
Doesn't count as hazardous waste generation
Often free or even revenue-generating
Environmentally beneficial
Simple regulations for small generators
What qualifies as used oil:
Motor oil (engines, transmissions)
Hydraulic fluids
Cutting oils and metalworking fluids
Turbine oils
Compressor oils
What doesn't qualify:
Oil mixed with solvents or other hazardous waste (becomes hazardous waste)
Oil mixed with significant water or antifreeze
Bottom sludge from tanks (may be hazardous waste)
Keep used oil separate from other wastes to maintain recycling eligibility.
What training is required for VSQG employees?
Federal RCRA: No specific training requirements for VSQGs.
However, good practice includes:
Basic orientation on what constitutes hazardous waste
Proper container use and labeling
Storage location and safety
Spill response procedures
Who to contact with questions
Other regulations may require training:
OSHA Hazard Communication (safety data sheets, labeling)
OSHA training for specific hazards
DOT training if employees transport waste
State-specific requirements
We provide training materials and guidance to help VSQGs implement appropriate staff training even when not strictly required.
What about home-based businesses?
Home businesses generating hazardous waste are still VSQGs (if under thresholds) and must:
Not dispose of hazardous waste in household trash
Not pour solvents or chemicals down home drains
Use legitimate disposal services
Follow storage requirements
Comply with local zoning and regulations
Special considerations:
Household hazardous waste programs may accept small quantities
Separate business waste from household waste
Local regulations on operating home businesses
Homeowner association rules
Insurance considerations
Common home-based VSQGs:
Art studios (solvents, paints, fixatives)
Woodworking shops (stains, finishes)
Photography studios (chemistry if not digital)
Small-scale manufacturing
Electronics repair
Jewelry making (acids, solvents)
State-by-State VSQG Variations
While federal VSQG rules provide baseline, states can be more stringent.
States with Additional VSQG Requirements
EPA ID numbers required for VSQGs (called "generator identification number")
Registration with DTSC or local agency
Annual fees in some jurisdictions
Tiered fees based on generation (even for VSQGs)
Enhanced enforcement
EPA ID number recommended
Must use permitted transporters and facilities
Some counties have additional requirements
New York City has strict waste regulations
Comprehensive VSQG regulations
Must use manifest or alternate tracking document
Waste must go to permitted facilities
Enhanced documentation requirements
VSQG notification recommended
Must use permitted facilities
Enhanced enforcement in some areas
Registration recommended
Must use licensed transporters
Specific waste ban requirements
Dangerous waste regulations (state equivalent of RCRA)
Some additional requirements for small generators
Notification requirements in some counties
Must use authorized facilities
County-specific regulations vary
States with Minimal Additional Requirements
Many states follow federal VSQG rules closely with few additional requirements:
Texas
Ohio
Pennsylvania (outside Philadelphia)
Michigan
Indiana
Most Midwest and Southern states
How to Check Your State Requirements
Visit state environmental agency website - search for "hazardous waste" and "small generator" or "VSQG"
Call state agency - they can explain requirements
Contact us - we know state regulations nationwide and can advise on your specific state
Check local requirements - some cities and counties have additional rules
The Bottom Line: VSQG Compliance Made Simple
Being a Very Small Quantity Generator provides significant regulatory relief, but you still have responsibilities:
Your Core VSQG Responsibilities:
Identify your hazardous waste - know what you're generating
Stay under limits - less than 100 kg/month hazardous waste, less than 1 kg/month acutely hazardous
Store safely - proper containers, labeling, location
Use legitimate disposal - permitted facilities only, never illegal disposal
Keep records - document proper disposal protecting yourself
Check state rules - ensure compliance with state requirements
Benefits of Proper VSQG Management:
Legal Protection:
Avoid penalties and fines
Reduce liability
Demonstrate environmental responsibility
Cost Savings:
Avoid cleanup costs from improper disposal
Minimize waste through good practices
Prevent expensive regulatory violations
Safety:
Protect employees from hazardous materials
Prevent accidents and spills
Create safer workplace
Environmental Stewardship:
Protect public health and environment
Demonstrate corporate responsibility
Contribute to sustainability
When to Get Professional Help:
Contact a hazardous waste professional if you:
Are unsure if waste is hazardous
Don't know how to properly dispose of materials
Are approaching or exceeding VSQG limits
Face an inspection or enforcement action
Need training for employees
Are expanding operations and waste will increase
Have questions about state requirements
Need to dispose of unusual or difficult waste
Get Expert Help with VSQG Compliance
At Hazardous Waste Disposal, we specialize in helping VSQGs across all industries manage their hazardous waste properly and cost-effectively.
Our VSQG Services:
Waste Identification and Characterization:
Help determine if your waste is hazardous
Classify waste for proper disposal
Provide guidance on segregation
Disposal Services:
Scheduled or on-call pickup
Proper containers and labeling
Certified disposal at permitted facilities
Certificates of destruction/disposal
Compliance Support:
Guidance on federal and state requirements
Help with EPA ID number applications
Training materials for staff
Spill response advice
Cost Optimization:
Waste minimization recommendations
Recycling opportunities
Right-sized service for your needs
Competitive pricing
Contact Us Today:
Call (800) 582-4833 or email info@hazardouswastedisposal.com
We serve VSQGs nationwide in all industries. Whether you're disposing of waste for the first time or looking to optimize your current program, we provide expert, compliant, cost-effective solutions.
Serving businesses nationwide, since 1992 - Your partner in hazardous waste compliance
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.