All Small Quantity Generators (SQG) are required to re-notify the Environmental Protection Agency (EPA) of their generator status every four (4) years by utilizing the Notification of Resource Conservation and Recovery Act (RCRA) Subtitle C Activities Site Identification Form (Form 8700-12). You can download
EPA Form 8700-12 on EPA’s website and the
due date is September 1, 2025.
A SQG generates, in any calendar month:
- > 100 kilograms, but < 1,000 kilograms (> 220 pounds, but < 2,200 pounds) of non‐acute hazardous waste and
- ≤ 1 kilogram (2.2 pounds) of acute hazardous waste and
- ≤ 100 kilograms (220 pounds) of any acute hazardous spill cleanup material
For additional information on the rules and regulations which require SQG to re-notify every four (4) years, please refer to:
In addition to complying with the federal regulations for SQGs, your facility also needs to comply with any state-specific regulations for SQGs. Trinity suggests a review of your obligations under your state’s
Hazardous Waste Programs. In states where there is a more frequent SQG re-notification requirement, the SQG must comply with the state deadline. Some states also have their own forms that are equivalent to EPA Form 8700-12. In these states, re-notification using the state-specific form meets the requirement of the federal regulation.
Submittal of the re-notification is completed by following one (1) of the following methods:
- Through a state-specific portal (refer to Hazardous Waste Programs) or
- Through utilization of a paper version of a state-specific form or
- Through utilization of the paper version of EPA Form 8700-12 or
- Through utilization of RCRAInfo
Key points for the SQG re-notification document (due September 1, 2025) include the following:
- EPA first required SQGs to re-notify by September 1, 2021. Therefore, your facility’s EPA Form 8700-12, or state-specific form from 2021 will serve as a good starting point to completing this re-notification (due September 1, 2025).
- On EPA Form 8700-12, the Reason for Submittal box that must be checked is, ‘Obtaining or updating an EPA ID number for on‐going regulated activities (Items 10‐17 below) that will continue for a period of time.’
- A legal owner, operator or authorized representative for the company must certify the SQG re-notification (EPA Form 8700-12). 40 CFR §260 defines an authorized representative as ‘the person responsible for the overall operation of a facility or an operational unit (i.e., part of a facility), e.g., the plant manager, superintendent or person of equivalent responsibility.’
Additional requirements for SQG can be found throughout
40 CFR §262. Key requirements for SQGs include the following:
- The quantity of hazardous on-site waste must never exceed 6,000 kilograms (13,228 pounds).
- Hazardous waste can accumulate on-site for 180 days (or 270 days if shipping a distance greater than 200 miles).
- There must always be at least one (1) employee available to respond to an emergency.
- SQGs are required to have a simple Contingency Plan posted where hazardous waste is accumulated.
- Preparedness and prevention requirements apply to all areas where hazardous waste is generated.
Trinity suggests that a generator re-assess their hazardous waste generator status monthly. This exercise includes reviewing generation records, accumulation records, and manifests for your facility.
Instead of meeting the definition of a SQG, your facility may instead qualify as a Very Small Quantity Generator (VSQG) or a Large Quantity Generator (LQG):
A VSQG generates, in any calendar month:
- ≤100 kilograms (220 pounds) of non‐acute hazardous waste and
- ≤ 1 kilogram (2.2 pounds) of acute hazardous waste and
- ≤ 100 kilograms (220 pounds) of any acute hazardous spill cleanup material.
A LQG generates, in any calendar month:
- ≥ 1,000 kilograms (2,200 pounds) of non‐acute hazardous waste or
- > 1 kilogram (2.2 pounds) of acute hazardous waste or
- > 100 kilograms (220 pounds) of any acute hazardous spill cleanup material.
Please note that some states located on this
Hazardous Waste Generator Category Table have different thresholds and category definitions from the Federal Categories (as noted above for VSQG, SQG, and LQG).
If your generator re-assessment results in a different generator category, there may be notification and/or registration requirements, and potentially additional compliance requirements based on this new type of generator. For facilities that bounce between SQG and LQG status, it is common practice to register as a LQG in order to avoid any compliance pitfalls. Also, please keep in mind that sometimes an incident bumps a generator that is normally an SQG or VSQG into a larger generator category for a short period. EPA calls this an “episodic event” and it can happen because of a process cleanout, a small project, or even a spill. If this happens to you, there is a streamlined set of “episodic event” waste generator requirements designed to keep you from having to comply with additional regulations because of an uncommon event.
Trinity is standing by to assist with your waste generator questions and can develop a compliance plan that includes all state and federal regulations for that specific type of hazardous waste generator in that specific state.
Please take a moment to mark September 1, 2025 on your calendars for the SQG re-notification due date!
For further assistance with or information regarding Hazardous Waste Compliance, please contact:
