Compliance
Very small quantity generator requirements
The lightest category, what it still requires, and the limits that quietly end it.
A very small quantity generator produces no more than 100 kg of hazardous waste and no more than 1 kg of acute hazardous waste in a calendar month. VSQGs have no accumulation time limit and no manifest requirement in most states, but must not accumulate more than 1,000 kg on site.
Source: 40 CFR 262.14What a VSQG must still do
- Make an accurate hazardous waste determination for every stream, under 40 CFR 262.11
- Stay under 1,000 kg of hazardous waste on site at any time
- Stay under 1 kg of acute hazardous waste on site at any time
- Send waste only to a permitted, licensed or authorized facility
- Not treat, store or dispose of hazardous waste in a way that requires a permit
Several states are more stringent than the federal baseline and require EPA identification numbers, manifests or notification from VSQGs. The federal rule is the floor.
Where VSQG status usually breaks
Two things end VSQG status in practice. The first is a one off event: a tank cleanout, a laboratory decommissioning, a discontinued product batch. The month's generation crosses 100 kg and the site is an SQG or LQG for that month.
The second is acute waste. The 1 kg threshold is roughly two pounds, and a single P listed container plus its triple rinsate can pass it. A site that thinks of itself as a VSQG can become an LQG for a month without generating a single additional drum of ordinary waste.
Neither is a problem if it is recognized. Both are a problem if the first time anyone notices is during an inspection.
Common questions
Do VSQGs need an EPA ID number?
Not under the federal rule, but many authorized states require one. Check the state program before assuming. Several Southeast states require notification even where the federal rule does not.
Can a VSQG send waste to an LQG under common control?
Yes. The 2016 Generator Improvements Rule allows a VSQG to send hazardous waste to an LQG under the control of the same person, provided the LQG notifies EPA and meets the conditions at 40 CFR 262.14(a)(5)(viii).
Is there a time limit on VSQG accumulation?
No time limit federally, but there is a quantity limit. Once 1,000 kg is on site, the site is no longer a VSQG and the accumulation rules for the higher category apply.
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.