Waste Management Program
Address
Division of Environmental Quality
P.O. Box 176
Jefferson City, MO 65102-0176
United States
Email
This fact sheet provides general information to help Very Small Quantity Generators (VSQG) manage their hazardous waste safely and legally. It is for general guidance only. Businesses should refer to the appropriate state and federal laws and regulations to determine compliance.
What is hazardous waste?
The Missouri Hazardous Waste Management Law requires all businesses to determine if a waste is a hazardous waste. To make this determination, first determine if the material is a solid waste according to the definition in Code of Federal Regulations (CFR) 40 C.F.R. § 261.2. A material does not have to physically be a solid to be considered a solid wastes. Solid waste includes the following materials:
- Materials that have been or are intended to be thrown away
- Materials being stored indefinitely (speculative accumulation)
- Recycled materials
- Inherently waste-like materials
- Waste military weapons and ammunitions that are solid waste as identified in 40 C.F.R. § 266.202
A hazardous waste is any solid waste that is flammable, corrosive, reactive, toxic or is listed (identified) as a hazardous waste in federal or state regulations. Hazardous waste listings and definitions are located in 40 C.F.R. §§ 261.20 through 261.35.
What is a VSQG?
Many businesses and institutions generate hazardous waste. Federal and state regulations require hazardous waste generators to meet standards for handling hazardous waste. The federal regulations are located in 40 C.F.R. § 262.14. The state regulations are located in the Missouri Code of State Regulations (CSR) 10 CSR 25-5.262. The standards the generator must follow depend on the amount and type of hazardous waste generated in one calendar month or accumulated at any one time.
Businesses generating or accumulating very small amounts of hazardous wastes are VSQGs and might be exempt from many, but not all, of the generator standards. A business is a VSQG if it meets all of the following conditions:
- Generates 100 kilograms or less (approximately 220 pounds) of non-acute hazardous waste in one calendar month
- Generates 1 kilogram or less (approx. 2.2 pounds) of acute hazardous waste in one calendar month
- Accumulates 1 kilogram or less (approx. 2.2 pounds) of acute hazardous waste at any one time
- Generates 100 kilograms or less (220 pounds) of any residue or contaminated soil, water or other debris resulting from the cleanup of a spill, into or on any land or water, of any acute hazardous waste in one calendar month
- Accumulates 100 kilograms or less (220 pounds) of any residue or contaminated soil, water or other debris resulting from the cleanup of a spill, into or on any land or water, of any acute hazardous waste in one calendar month
Businesses not meeting all of the above conditions, must register with the department as a hazardous waste generator. A business that exceeds the accumulation limits outlined above becomes subject to the requirements 40 C.F.R. §§ 262.14(a)(3) or (4).
Is a VSQG required to register as a hazardous waste generator?
There are no laws requiring a VSQG generating less than the amounts outlined above to register as a hazardous waste generator. A VSQG becomes subject to registration as a VSQG in the event that it accumulates more than 1 kilogram of acute hazardous waste or 100 kilograms of residue from a cleanup of a spill of acute hazardous waste at one time. Some hazardous waste facilities prefer customers to have generator identification numbers. Businesses needing a generator identification number must complete the Notification of Regulated Waste Activity (NORWA) MO 780-1164 form. The NORWA form may also be completed online through the Missouri Gateway for Environmental Management (MoGEM) online portal.
Print and mail the completed form with original ink signature and the required fee to the department. The associated fee is required for new registrations and reactivating registrations. Registering as a generator does not require a business to follow any additional laws. Registration simply allows a business to get a generator identification number.
How can a VSQG manage their hazardous waste?
According to Missouri Revised Statutes (RSMo), section 260.432.5(2), RSMo, Missouri sanitary landfills are not allowed to accept any but the very smallest amounts of hazardous waste. This ban affects VSQGs by requiring them to find alternatives to sanitary landfill disposal. VSQGs are allowed to dispose of their hazardous waste in an off-site permitted treatment, storage and disposal (TSD) facility or another facility approved by the state.
Whichever way it is decided to manage the businesses’ hazardous waste, remember Missouri law requires management of all wastes in a manner that does not threaten human health or the environment or create a public nuisance. Preventing pollution through source reduction and recycling is a better management option than treatment or destruction technologies and land disposal.
The management options described below are listed in order of the most desirable option first and the least desirable option last.
Option 1: Pollution Prevention
Pollution prevention is using materials or procedures that reduce or stop pollutants or waste at the start of production. It includes practices that reduce the use of hazardous or nonhazardous materials, energy, water or other resources. It also includes activities that protect natural resources through conservation or by more efficient use. Many pollution prevention activities are simple and inexpensive, often resulting in large dollar savings.
Option 2: Waste Exchange
Waste exchanges put hazardous waste generators with usable wastes in touch with companies who might be able to use the waste as a raw material for their manufacturing or production process. Missouri participates in the Industrial Material Exchange Service in conjunction with the Environmental Improvement and Energy Resources Authority (EIERA).
Option 3: Business and Trade Association Cooperative
Businesses might be able to reduce transportation and disposal costs by making shared arrangements with other businesses in their area or asking for help from a trade association to which they belong. Possibilities include the following:
- Work with other VSQGs in the area to arrange a set schedule with a licensed hazardous waste transporter to pick up the hazardous wastes from all VSQGs in the group. Picking up more hazardous waste with fewer runs typically means lower costs for transportation and disposal.
- If a generator belongs to a business or trade association, ask if the organization could help arrange pick up and disposal based on an entire group being represented in the bid process.
- Talk to several hazardous waste transporters and TSD facilities about the most economical methods to manage waste, based on type and frequency of production. A group of potential VSQG customers may be encouraged to have transporter or transfer facility pick-ups and disposals or “at facility drop-off days.”
Option 4: Recycle
Recycling helps to preserve raw materials and reduce the amount of waste disposed of. Many recycling companies accept specific waste streams, such as solvents or used oils, to recycle at their facility. To make it easier to recycle hazardous waste, keep different waste streams in separate containers and separate nonhazardous waste from hazardous waste.
Some hazardous material that would normally be disposed of as waste can instead be reclaimed and managed as hazardous secondary material. However, the generator will need to comply with the regulations in 40 C.F.R. § 261.4(a)(23) if the generator is managing the waste themselves, or 40 C.F.R. § 261.4(a)(24) if the generator is using another person to transport or reclaim the material.
Purchase recycling equipment to use on-site, such as equipment for distilling contaminated solvents. This equipment may pay for itself over time by reducing the amount of new product bought and lowering disposal costs by reducing the amount of waste requiring disposal. When recycling on-site, there may be residual waste requiring hazardous waste disposal.
VSQGs are not required to get a permit or certification to recycle waste on-site, but the department’s Waste Management Program must be notified in writing of recycling activities. In the notification, list the following information:
- Owner or operator
- Name and location of the facility
- Waste(s) being recovered
- Method(s) of recovery
- Approximate amount of waste recovered yearly
Option 5: Universal Waste Rule
The Universal Waste Rule became effective in Missouri on Jan. 31, 1999. Hazardous waste batteries, pesticides, mercury containing thermostats, mercury switches, manometers, fluorescent and incandescent lamps and aerosol cans can be managed under this rule. The requirements of this rule are generally less stringent than the existing hazardous waste regulations.
Option 6: Publicly Owned Treatment Works System
If a business is located in an area serviced by a publicly owned treatment works (POTW) system for wastewater and sewage it may be legal to release certain hazardous waste into the sanitary sewer system. Do not release any waste into the sanitary sewer system without the POTW’s permission. Contact local wastewater officials to discuss the type of waste stream, pretreatment requirements and local ordinances that may apply. Retain written documentation of permission to discharge the hazardous waste into the sanitary sewer system. Many wastes cannot be released into a sanitary sewer system. Solvents, sludges and pesticides may not be suitable for release. Do not release any hazardous waste into a storm water drain or on-site domestic sewage treatment system.
Option 7: Hazardous Waste TSD Facility
If none of the previously mentioned options are possible, send the hazardous waste to a facility that can treat, store or dispose of hazardous waste. These facilities must have either a valid hazardous waste permit or interim status approval from the U.S. Environmental Protection Agency (EPA) to do business as a hazardous waste TSD facility. Missouri facilities must have a valid permit or interim status approval from the department. A list of Missouri commercial TSD facilities is located in the fact sheet, Missouri Commercial Hazardous Waste Facilities - PUB968. For a list of commercial TSD facilities in another state, contact the hazardous waste regulatory agency in that state.
Before shipping waste, contact the facility to verify its current operating status and find out if it can accept the waste. If possible, visit the facility before shipping waste. Learn about the facility’s treatment or disposal process and find out if the facility manages waste properly. If a site visit is not possible, contact the appropriate state regulatory agency and ask about the facility’s compliance history and current regulatory status. Hazardous waste transporters can also be a valuable source of information on facilities currently accepting hazardous waste.
How should a VSQG transport their hazardous waste?
VSQGs may transport their own hazardous waste within Missouri to a facility permitted or certified to accept hazardous waste. A manifest or a licensed hazardous waste transporter is not required for self-transporting as long as the threshold amounts of hazardous waste to remain a VSQG are not exceeded. U. S. Department of Transportation requirements may apply to the wastes being shipped.
If a VSQG does not choose to transport its waste, a Missouri licensed hazardous waste transporter is required. The department maintains a list of licensed hazardous and infectious waste transporters. Hazardous waste transporters may transport VSQG waste only to a facility permitted or certified to accept the waste. The transporter must keep records on the type, amount, source and character of each waste accepted from a VSQG.
Can a VSQG consolidate their waste?
VSQGs that are part of a larger company may consolidate the VSQG hazardous waste at a Large Quantity Generator (LQG) owned by the same company. Consolidating reduces the VSQGs overall environmental liability and waste management costs and improves the management of their hazardous waste. To participate in this option, both the LQG and the VSQG must be located in Missouri and must be under the control of the same company. The VSQG also must stay within the generation and accumulation limits for VSQGs.
At least 30 days before receiving the first shipment from a VSQG, the LQG must notify the department of its plans to consolidate waste using the NORWA form and complete the Addendum B “LQG Consolidation of VSQG Hazardous waste Notification.” The participating VSQG should mark its containers with the words “Hazardous Waste” and proper indication of the hazards of the contents. The VSQG would ensure delivery of the waste to the LQG. The LQG would then manage the VSQG waste alongside the waste it generates as an LQG, making sure to follow all LQG requirements.