Compliance
Hazardous waste generator status
The three categories, what sets them apart, and why your status can change from one month to the next.
Generator status is set by how much hazardous waste you generate in a calendar month. Very small quantity generators produce up to 100 kg, small quantity generators 100 to 1,000 kg, and large quantity generators 1,000 kg or more. Status determines accumulation limits, reporting duties and inspection expectations.
Source: 40 CFR 262.13The three categories side by side
Counting is per calendar month, per site, and it includes all hazardous waste generated, not just what you ship.
| Category | Monthly generation | Accumulation limit | On site quantity limit |
|---|---|---|---|
VSQG | Up to 100 kg | No time limit | 1,000 kg |
SQG | 100 to 1,000 kg | 180 days, 270 if over 200 miles | 6,000 kg |
LQG | 1,000 kg or more | 90 days | No limit |
The acute waste threshold cuts across all three
- More than 1 kg of acute hazardous waste in a month makes you an LQG for that month
- More than 100 kg of acute spill residue in a month does the same
- Acute waste is P listed material and a small number of specific F listings
- One discarded container of a P listed chemical can cross the threshold
Status is determined per site and per month. A facility that generates 1,100 kg in March is an LQG for March, with all the duties that brings, even if it generates 40 kg in every other month of the year.
What actually changes between categories
The obvious difference is time. An LQG has 90 days to move waste off site, an SQG has 180, and a VSQG has no clock at all. The less obvious differences cost more. LQGs file biennial reports, maintain a written contingency plan, run arrangements with local emergency responders, and carry personnel training obligations. SQGs have a lighter version of each. VSQGs have almost none.
The trap is drifting upward without noticing. A one off project, a tank cleanout, a discontinued product disposal, and the month's total crosses a threshold. The duties attach to that month, and an inspector looking back at manifests can see it plainly.
Common questions
Does used oil count toward my generator status?
Not if it is managed under the used oil standards at 40 CFR Part 279. Used oil destined for recycling is regulated separately and does not count toward the monthly generation total. Used oil that is mixed with hazardous waste is a different matter.
What if my generation varies month to month?
Status is determined month by month. You meet the requirements for whichever category applies in that month. Episodic generation provisions at 40 CFR Part 262 Subpart L allow a planned or unplanned episode without a permanent category change, provided the conditions are met.
Is status per company or per site?
Per site. Each physical location with its own EPA identification number is evaluated separately. A company with five plants can hold three different generator categories at once.
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.