Compliance
Small quantity generator requirements
The middle category, the 180 day clock, and the requirements that come with it.
A small quantity generator produces between 100 and 1,000 kg of hazardous waste in a calendar month. SQGs may accumulate waste for up to 180 days, or 270 days if the waste must travel more than 200 miles for treatment, and may hold no more than 6,000 kg on site.
Source: 40 CFR 262.16SQG obligations
- Obtain an EPA identification number
- Accumulate for no more than 180 days, or 270 days if shipping over 200 miles
- Hold no more than 6,000 kg on site at any time
- Manifest every shipment on EPA Form 8700-22
- Mark containers with the words Hazardous Waste and the accumulation start date
- Inspect accumulation areas weekly
- Maintain basic emergency procedures and post emergency information by the telephone
- Ensure employees are thoroughly familiar with proper handling and emergency procedures
- Re-notify EPA every four years
The 270 day extension
An SQG that must ship waste more than 200 miles for treatment or disposal gets 270 days rather than 180. The distance is to the designated receiving facility, and the extension is automatic rather than something to apply for.
It matters in the Southeast, where specialized treatment capacity is concentrated in relatively few locations. A site in south Alabama shipping to a Texas or Ohio facility is frequently over 200 miles, and the extra 90 days can be the difference between one consolidated shipment and two partial ones.
Common questions
Does an SQG need a written contingency plan?
No. SQGs need basic emergency procedures, an emergency coordinator, and emergency information posted by the telephone, but not the full written contingency plan an LQG must maintain under 40 CFR 262.261.
What happens if I exceed 180 days?
The site is storing hazardous waste without a permit, which is a significant violation. If a genuine circumstance beyond your control causes the delay, an extension of up to 30 days may be granted at the discretion of the regulator, but it has to be requested.
How is the 200 mile distance measured?
To the designated facility that will treat, store or dispose of the waste, as named on the manifest. If you use more than one receiving facility, the applicable limit follows the destination for that shipment.
Related services
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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.