Waste Management Program fact sheet
Division of Environmental Quality Director: Art Goodin
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Generator Categories

Businesses producing hazardous waste must follow certain federal and state laws and regulations. The laws and regulations applying to those businesses depend on the amount and type of hazardous waste generated. There are three waste generator categories:

  1. Very Small Quantity Generators (VSQGs) do all of the following:
    • Generate 100 kilograms (kg) (approximately 220 pounds) or less of hazardous waste in one calendar month
    • Generate 1 kg (approximately 2.2 pounds) or less of acutely hazardous waste in one calendar month
    • Accumulate less than 1 kg of acute hazardous waste and less than 100 kg of residue or contaminated soil from cleanup of an acute waste spill at any one time
  2. Small Quantity Generators (SQGs) do any of the following:
    • Generate more than 100 kg (approximately 220 pounds) but less than 1,000 kg (approximately 2,200 pounds) of hazardous waste in one calendar month
    • Generate 1 kg (approximately 2.2 pounds) or less of acutely hazardous waste in one calendar month
    • Accumulate less than 1 kg of acute hazardous waste at any one time
    • Accumulate less than 6,000 kg (approximately 13,200 pounds) of hazardous waste.
  3. Large Quantity Generators (LQGs) do any of the following:
    • Generate 1,000 kg (approximately 2,200 pounds) or more of hazardous waste in one calendar month
    • Generate more than 1 kg (approximately 2.2 pounds) of acutely hazardous waste or more than 100 kilograms per month of residue or contaminated soil from cleanup of an acute hazardous waste spill

A business’ acute hazardous waste cannot be managed separately from other hazardous wastes. For example: LQG status cannot be maintained for acute waste and then maintain SQG status for all other hazardous wastes. Failing to meet any single criteria noted in a generator category above will cause the facility to fall into one of the larger generation categories.

Change in Generator Status

Businesses generating or accumulating greater than 100 kg of hazardous waste, or 1 kg or more of acutely hazardous waste, are required to register with the Missouri Department of Natural Resources. VSQG facilities that accumulate more than 1 kg of acute hazardous waste, or 100 kg of any residue or soil from a clean up of acute hazardous waste, are subject to registration and the requirements of Code of Federal Regulations 40 C.F.R. § 262.14(a)(3).

Episodic Generators

Many businesses experience a one-time hazardous waste generation event where they produce more hazardous waste than their current generator status. This event could be caused by a change in product line, production error, product recall, spill cleanup, inventory clean-out or similar event. When this occurs and a VSQG or SQG generates over the amount of hazardous waste for its generator category, the generator must comply with the standards for episodic generation events found in 40 C.F.R. Part 262 Subpart L.

When this type of event occurs, it can be considered an episodic event if it occurs only once in a calendar year, unless a petition is granted, and the generator does not store the extra waste for more than 60 days. Episodic generation can be either planned or unplanned. Planned episodic event notifications must be submitted to the department no later than 30 days before initiating the planned event. Generators must notify the department of an unplanned episodic event within 72 hours of the event.

A business may send notification by submitting an updated Notification of Regulated Waste Activity (NORWA) form, checking and dating the episodic generation Section 11.G. on the fifth page of the form and submitting it by mail to:

Missouri Department of Natural Resources
Waste Management Program
PO Box 176
Jefferson City, MO 65102-0176.

Be sure to include all of the following additional information in the comment section of the NORWA or in a cover letter accompanying the form:

  • An updated NORWA
  • Reason for the extra hazardous waste
  • Estimated amount of extra waste
  • Start and end date of the event
  • Facility contact and emergency coordinator with 24-hour telephone access with whom to discuss the event

If a business notifies the Department of its episodic event immediately, it may continue to provide an annual Generator Summary Report. 

Inspectors may check hazardous waste records to make sure a business is classified in the correct hazardous waste generator category and is following the regulations for that category. Business operations can be simplified by remaining classified as a LQG if the business believes it will repeatedly cross the generator limits between VSQG, SQG and LQG.

Example Episodic Generator

A VSQG plans to perform a one-time clean out of its maintenance shed. Over 100 kg of hazardous waste is expected to be produced as a result of the clean out. The business must submit a notification of the planned episodic event with the department at least 30 days before the beginning of the event. During the duration of the event, the facility must comply with the requirements of 40 C.F.R. Part 262 Subpart L.

Additional Information

Nothing in this document may be used to implement any enforcement action or levy any penalty unless promulgated by rule under chapter 536 or authorized by statute.

For more information