To determine which category of hazardous waste generator your business falls into, and what requirements you must meet, measure or count the hazardous wastes your business generates during a month; the total weight will determine your generator category.
If you decide to accumulate hazardous waste until you have collected enough to make transport to a licensed hazardous waste management facility more economical, be sure that you know these rules.
Large Quantity Generator
If you generate 1000kg (about 2,200 pounds) or more of hazardous waste, or more than 1 kg of acutely hazardous waste in any month, you are a Large Quantity Generator. You are required to comply with the annual training requirements of Title 40, CFR Chapter 1 by formally training at least one employee to be the facility Emergency Coordinator, and additionally to have at least one employee trained in hazardous waste management.
Small Quantity Generator
If you generate 100 or more and less than 1000 kg ( between 220 and 2,200 pounds) of hazardous waste or no more than 1 kg of acutely hazardous waste in any month, you are a Small Quantity Generator. You must comply with the requirements of Title 40, CFR Chapter 1 by formally training at least one employee to be the facility Emergency Coordinator.
Conditionally Exempt Small Quantity Generator
If you generate less than 100 kilograms (about 220 pounds) of hazardous waste in every calendar month, you are a Conditionally Exempt Small Quantity Generator. You are not required to comply with any annual training outlined in 40 CFR Chapter 1, as long as you never accumulate more than 1000 kg of hazardous waste on your property.
* * * Caution * * *
A very few states have different criteria for these categories.
Who Can Train Who?
The regulations state that training “…must be directed by a person trained in hazardous waste management procedures, and must include instruction which teaches facility personnel hazardous waste management procedures..”.
It’s a Catch-22 situation. The EPA requires that you get this training; however, they don’t tell you where or how to get it. The government does not provide this training for you, but at the same time, they require you to receive this training. You can conduct the training yourself, but only if you have been trained in the past year, by someone with the proper training credentials. And for every day that you are not in compliance with these regulations, you could be fined up to $50,000!
In addition to a law degree, I’ve been doing this training across America for the past 20 years. I am uniquely qualified to train you and look forward to that opportunity.