Free Tool

Generator Status Classifier

Enter your monthly hazardous waste volumes to determine whether your facility is VSQG, SQG, or LQG, along with the storage, manifest, and training rules that follow.

kg

Standard hazardous waste (e.g. solvents, oils, heavy metals).

kg

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.

kg

Contaminated soil or debris from cleanup of an acute waste spill. LQG threshold: >100 kg.

Enter waste volumes to see your classification.

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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.

What changes with your status?

Moving from SQG to LQG isn't just about volume—it's a massive jump in regulatory overhead.

Accumulation Limits

VSQGs must never exceed 1,000 kg total on-site. SQGs are capped at 6,000 kg. LQGs have no weight limit.

Storage Time Limits

VSQGs have no fixed federal accumulation time limit while they stay within VSQG quantity limits. SQGs have 180 days (or 270 if the TSDF is over 200 miles away). LQGs have only 90 days before waste must be shipped.

Documented Training

LQGs require annual, formal hazardous waste training for all relevant personnel. SQGs require "basic familiarity" for staff who handle waste.

Frequently Asked Questions

Common questions about EPA Generator Status rules.

Does my generator status reset each month?

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.

What if my volume varies — do I use the worst month?

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.

What is episodic generation?

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.

What is acutely hazardous waste?

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.

What happens if I exceed my on-site accumulation limit?

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 $93,058 per day under RCRA.

Do SQGs and LQGs need to register for e-Manifest?

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.

Is the calculator methodology available?

Yes. This tool uses TypeScript helpers based on selected federal EPA RCRA generator and accumulation rules. The implementation is available on GitHub.

Track your deadlines automatically

Once you know your status, the hard part is tracking every drum's accumulation clock before it expires. RCRAReady does that automatically — with SMS and email alerts before any deadline.

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