RCRA Generator Categories: VSQG, SQG, LQG
Last reviewed · By Chad Griffith
EPA's Resource Conservation and Recovery Act (RCRA) classifies hazardous waste generators into three categories based on the monthly quantity of hazardous waste generated, with progressively more stringent operational and recordkeeping requirements at each tier. Per 40 CFR 262.13, the categories are Very Small Quantity Generator (VSQG, formerly CESQG), Small Quantity Generator (SQG), and Large Quantity Generator (LQG). Generator status determines applicable recordkeeping, training, contingency planning, and reporting obligations.
VSQG (Very Small Quantity Generator)
VSQGs generate less than 100 kg (about 220 pounds) of hazardous waste per month and less than 1 kg of acute hazardous waste per month. VSQGs face the lightest regulatory burden: no EPA ID number required, no manifest required for off-site shipments to qualified destinations, no mandatory training, no formal contingency plan. VSQGs must still ensure proper hazardous waste determination, manage waste safely, and ship to licensed facilities. On-site accumulation is limited to 1,000 kg of hazardous waste at any time.
SQG (Small Quantity Generator)
SQGs generate between 100 kg and 1,000 kg (220 to 2,200 pounds) of hazardous waste per month and less than 1 kg of acute hazardous waste per month. Required: EPA ID number, manifest for all off-site shipments, basic personnel training, emergency contingency procedures (less formal than LQG plan), 180-day on-site accumulation limit (270 days if shipping over 200 miles), and accumulation containers must be marked with start dates and 'Hazardous Waste' labels.
LQG (Large Quantity Generator)
LQGs generate 1,000 kg or more of hazardous waste per month, or more than 1 kg of acute hazardous waste per month. Required: EPA ID number, manifest for all shipments, comprehensive personnel training program (initial training within 6 months plus annual refresher), formal written contingency plan with emergency procedures, 90-day on-site accumulation limit, biennial reports to EPA (Form 8700-13B), land disposal restriction (LDR) notifications, and additional procedural requirements at accumulation areas.
Recordkeeping Periods
Per 40 CFR 262.40, generators must retain a copy of each manifest signed by the transporter for at least three years from the date the waste was accepted by the initial transporter. Generators must also retain a copy of each manifest signed by the designated facility (TSDF) for at least three years from the date the waste was accepted. Hazardous waste determinations under 40 CFR 262.11 must be retained for three years from the date the waste was last sent off-site. Records of training (LQG) must be retained for three years from the date the employee last worked at the facility.
Episodic Generation
40 CFR 262 Subpart L (the Hazardous Waste Generator Improvements Rule) created an Episodic Generation provision allowing VSQGs and SQGs to maintain their generator category during a single, planned or unplanned event that would otherwise bump them into a higher category. Episodic generators must notify EPA before the event (planned) or within 72 hours (unplanned), comply with several SQG-equivalent requirements during the event, and complete waste removal within 60 days.
Frequently Asked Questions
How is generator status determined?
Generator status is determined per calendar month based on the total quantity of hazardous waste generated at a single site. Status can change month to month — a generator that crosses a threshold for a single month must comply with the higher-tier rules for that month. Some states use the highest-tier classification ever achieved as the operating status (no return to lower tier without re-notification).
What is acute hazardous waste?
Acute hazardous wastes are listed in 40 CFR 261.33(e) and carry the 'P' waste code. They include extremely toxic substances such as cyanides, certain pesticides, and specific industrial chemicals. The threshold for acute waste is much lower (1 kg per month for SQG, 1 kg per month for LQG triggers) because of their hazard severity.
How long must hazardous waste manifests be retained?
Per 40 CFR 262.40, generators must retain manifest copies for at least three years from the date the waste was accepted by the initial transporter. Both the transporter-signed copy and the TSDF-signed copy must be retained. Records must demonstrate continuous chain of custody. State retention requirements may exceed three years.
What is the e-Manifest system?
EPA's e-Manifest system, launched June 2018 under 40 CFR 262.20-25, allows electronic submission of hazardous waste manifests. The system replaced state-by-state paper systems and provides a national electronic record. Per-manifest fees in 2025-2027: $20 for fully electronic, $25 for hybrid, $35 for image upload, $80 for paper mail-in. Generators may use paper manifests but must scan and upload to e-Manifest within 30 days.
Authoritative sources