Hazardous Waste Manifest Guide: Who Signs and What to Keep (2026)
The hazardous waste manifest travels with each shipment to the disposal facility. This guide explains the form, who signs it, how long to...
Enter your monthly hazardous waste volumes to see whether you are a VSQG, SQG, or LQG, and the storage, manifest, and training rules that follow.
Standard hazardous waste (e.g. solvents, oils, heavy metals).
LQG threshold: >1 kg (2.2 lbs). Exactly 1 kg does not trigger LQG by itself. Includes P-listed and certain F-listed acute wastes.
Contaminated soil or debris from cleanup of an acute waste spill. LQG threshold: >100 kg.
Enter waste volumes to see your classification.
RCRA PFAS proposal watch
EPA has proposed listing nine PFAS compounds as RCRA hazardous constituents under Appendix VIII. As of EPA's May 7, 2026 update, the rule remains a proposal. If finalized, it would support corrective action at RCRA treatment, storage, and disposal facilities, but would not by itself make PFAS wastes listed hazardous wastes or change generator status.
Moving from SQG to LQG changes far more than your volume threshold.
VSQGs must never exceed 1,000 kg total on-site. SQGs are capped at 6,000 kg. LQGs have no weight limit.
VSQGs have no fixed federal time limit while within VSQG quantity limits. SQGs have 180 days (or 270 if the TSDF is over 200 miles away). LQGs have 90 days.
LQGs need annual, formal hazardous waste training for relevant personnel. SQGs need "basic familiarity" for staff who handle waste.
Common questions about EPA generator status rules.
Yes. Generator status is determined on a calendar-month basis under 40 CFR 262.13. You could be a VSQG in January, an LQG in February due to a cleanout, and an SQG in March. Each month is evaluated independently based on that month's generation volume.
No — you use each month's actual volume to determine status for that month. However, your compliance obligations (e.g., storage time limits, training, contingency plans) are tied to your highest status during any given month. If you're an LQG in February, you must comply with LQG rules for all waste generated that month, even if you drop back to SQG in March.
Episodic generation occurs when a VSQG or SQG temporarily generates more hazardous waste than its usual category allows, such as during a lab cleanout or spill. Under 40 CFR part 262 subpart L, a generator may maintain its existing category for one qualifying episodic event per calendar year if it meets the notice, labeling, manifest, shipment, and recordkeeping conditions.
Acutely hazardous wastes include P-listed commercial chemical products and certain F-listed wastes. Generating more than 1 kilogram (2.2 lbs) of acute hazardous waste in a single calendar month makes your facility a Large Quantity Generator (LQG), regardless of your non-acute waste volume. Generating exactly 1 kg does not trigger LQG status by itself under 40 CFR 262.13.
Exceeding your on-site limit (e.g., an SQG accumulating more than 6,000 kg, or a VSQG exceeding 1,000 kg) is a serious violation. The facility may be treated as an unpermitted Treatment, Storage, and Disposal Facility (TSDF) — which carries penalties up to $124,426 per day under RCRA.
Yes. As of January 22, 2025, SQGs and LQGs must maintain an EPA e-Manifest account with Site Manager or e-Manifest Certifier permissions. Receiving facilities are no longer required to mail final signed manifest copies back to SQGs and LQGs; those copies are accessed through e-Manifest. VSQGs are currently exempt from this registration requirement.
Yes. This tool uses TypeScript helpers based on selected federal EPA RCRA generator and accumulation rules. The implementation is available on GitHub.
RCRAReady tracks each container's accumulation clock and alerts you by SMS and email before it expires. 30 days free, no credit card.
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