Compliance
Accumulation and storage
The clocks, the container rules, and the inspections that get cited.
Generators may accumulate hazardous waste on site without a storage permit for a limited time: 90 days for large quantity generators, 180 or 270 days for small quantity generators, with no time limit for very small quantity generators.
Source: 40 CFR 262.15 through 262.17Accumulation limits by category
| Category | Time limit | Quantity limit | Extension available |
|---|---|---|---|
VSQG | None | 1,000 kg on site | Not applicable |
SQG | 180 days | 6,000 kg on site | 270 days if over 200 miles |
LQG | 90 days | No limit | 30 days at regulator discretion |
Container requirements, all categories
- Marked with the words Hazardous Waste
- Marked with an indication of the hazards, added by the 2016 Generator Improvements Rule
- Marked with the accumulation start date
- Kept closed except when adding or removing waste
- In good condition, compatible with the contents
- Inspected weekly for leaks and deterioration
Exceeding the limit is storage without a permit
The accumulation provisions are an exemption from the requirement to hold a storage permit. Exceed the time limit and the exemption no longer applies, which means the site is operating a storage facility without a permit.
That is a materially more serious finding than a labeling error. It is also easy for an inspector to establish, because the accumulation start date is written on the drum.
Common questions
When does the clock start?
For a central accumulation area, when waste is first placed in the container. For waste moved from a satellite area, from the date the satellite volume limit was exceeded.
Can I get an extension?
Up to 30 days may be granted at the regulator's discretion for circumstances beyond your control. It must be requested, and it is not automatic.
What counts as closed?
Secured so nothing can escape. A funnel sitting in an open bung is an open container. Latching funnels resolve this and are inexpensive. This is the most frequently cited container violation there is.
Related services
Not sure how this applies to your site?
Send a profile, an old manifest, or photographs of the drums. A technical professional will tell you where you stand.
This page summarizes federal requirements and is not legal advice. State programs can be more stringent than the federal baseline. Verify against current federal and state regulations before acting. Last reviewed September 2026.