RCRA (Resource Conservation and Recovery Act)
Last reviewed · By Chad Griffith
The Resource Conservation and Recovery Act (RCRA) is the principal US federal law governing the disposal of solid and hazardous waste, enacted in 1976 and amended substantially in 1984. RCRA is implemented through EPA regulations at 40 CFR Parts 239-282. Subtitle C governs hazardous waste from cradle to grave — generators, transporters, and treatment/storage/disposal facilities (TSDFs) — including waste identification (40 CFR 261), generator standards (262), transporter standards (263), and TSDF standards (264-265). Generators are categorized by monthly waste quantity: Very Small Quantity Generator (VSQG), Small Quantity Generator (SQG), and Large Quantity Generator (LQG), each with distinct recordkeeping and operational requirements. RCRA hazardous waste violations carry penalties up to $99,681 per day per violation under 2026 inflation-adjusted amounts.
Frequently Asked Questions
What are the three RCRA generator categories?
Per 40 CFR 262.13: (1) Very Small Quantity Generator (VSQG) — generates less than 100 kg of hazardous waste per month and less than 1 kg of acute hazardous waste per month; (2) Small Quantity Generator (SQG) — between 100 kg and 1,000 kg per month; (3) Large Quantity Generator (LQG) — 1,000 kg or more of hazardous waste per month, or more than 1 kg of acute hazardous waste per month. Recordkeeping and operational requirements scale with generator category.
How long must hazardous waste manifests be retained?
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 by the initial transporter. Retention must be continuous and provide demonstrated chain of custody.
What documents prove RCRA compliance?
Required RCRA documentation: hazardous waste determinations under 40 CFR 262.11 for each waste stream; manifests (Form 8700-22) for off-site shipments; biennial reports for LQGs (Form 8700-13); contingency plan and emergency procedures; personnel training records (initial and annual refresher); inspection records (typically weekly for waste accumulation areas); land disposal restriction (LDR) notifications; and any state-specific permits or notifications.
What is e-Manifest?
EPA's e-Manifest system, launched June 2018 under 40 CFR 262.20-25, allows electronic submission of hazardous waste manifests. EPA charges per-manifest fees that vary by submission type. The e-Manifest system replaced state-by-state paper systems and provides a single national electronic record. Generators may continue using paper manifests but must scan and upload to e-Manifest within 30 days. Per-manifest fees in 2025-2027: $20 for fully electronic, $25 for hybrid, $35 for image upload, $80 for paper mail-in.
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