Don’t Forget Your Hazardous Waste Biennial Report and Reduction Plan Due in 2026!

Environmental ConsultingEnvironmental Consulting
January 13, 2026
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The Resource Conservation and Recovery Act (RCRA) regulations establish basic hazardous waste management standards for facilities that produce hazardous waste, or hazardous waste generators, under 40 CFR Part 262. Similarly, Georgia regulates businesses that generate or store hazardous waste under the Hazardous Waste Management Act at Georgia Rule 391-3-11. Under RCRA, the biennial Hazardous Waste Report is required for all large quantity generators (LQG) of hazardous waste, and in Georgia, the Hazardous Waste Reduction Plan is required to be submitted in conjunction with this report. Although this report is required biennially, the report covers the prior calendar year’s hazardous waste details.

Facilities are considered LQG based on applicability during the prior calendar year, i.e. during 2025 for 2026 reporting. Small and very small quantity generators, including Short Term Generators, that were LQGs at any point in 2025 are required to complete both reports. Facilities who were previously notified as LQGs but did not generate LQG amounts of hazardous waste in 2025, must complete a Certification of Non-Filer form in lieu of the Biennial Report and must also complete a Waste Reduction Progress Report.

The biennial report and plan submittals are both due on March 1, 2026. The biennial report is submitted in RCRAInfo while the signed reduction plan must be emailed to Georgia EPD. The requirements for different categories of LQG of hazardous waste are included in Table 1.

Table 1
Existing LQG NEW LQG Short-Term LQG Previously Notified as LQG but Did Not Generate Over LQG Thresholds in 2025
Hazardous Waste Report Report required to be completed and filed Report required to be completed and filed Report required to be completed and filed Certification of Non-Filer Form to be completed and filed
Hazardous Waste Reduction Plan A Waste Reduction Plan has already been submitted in a prior biennial year. Submit Form I and Progress Report Create a Waste Reduction Plan detailing the current waste production at the facility and plans for future reduction. Submit the full plan Submit an abbreviated report, including Form I, Form II, and Progress Report A Waste Reduction Plan has already been submitted in a prior biennial year. Submit Form I and Progress Report

Unsure of your requirements under these regulations? Trinity Consultants can assist with categorization of hazardous waste generator status, review of waste information from disposers, preparation of the report, and completion of plan updates. Reach out to Trinity’s Atlanta office at 678.441.9977 or contact Manager of Consulting Services, Katie Brubaker. To learn more about waste management regulations, register for the Atlanta session of the Introduction to Waste Management and RCRA course on April 14.

Trinity has helped me train our staff and navigate the complexities of hazardous waste permitting and compliance with ease and efficiency. They have always delivered high-quality work on time and are very responsive and thorough whenever I’ve had any questions or concerns. I highly recommend Trinity to anyone who needs an advocate for agency interaction and reliable assistance with their hazardous waste management and permitting needs.

Director of Environment & Sustainability /Hazardous Waste Company

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