GLOBAL
ENVIRONMENTAL ASSURANCE INC.

Conditionally Exempt Small
Quantity Generator Requirements

Definition: A conditionally Exempt Small Quantity Generator (CESQG) produces no more than 100kg (220 lbs., usually about half of a 55-gallon drum) of hazardous waste in any calendar month.

Requirements: A CESQG is exempt from most hazardous waste regulations, except:

• The CESQG must determine whether his waste is hazardous, and
• A CESQG’s hazardous wastes must be treated or disposed in a permitted Facility or recycled, either on-site or off-site;

A CESQG is not required to:

• Notify EPA of hazardous waste activities;
• Have an EPA identification Number;
• Label or inspect the hazardous wastes while they are in his storage;
• Ship using a hazardous waste manifest (although most facilities receiving Such wastes require a manifest);
• Have a written Contingency Plan;
• Conduct RCRA personnel training (but may be subject to training Requirements under OSHA’s “HAZWOPER” regulations).

Exception: If a CESQG generates more than 100kg. In one month, or stores more than 1000kg. (2200 lbs., about 4-5 drums) of hazardous waste at any time, he becomes subject to requirements for generators of 100 to 1000 kg. (220 to 2200 lbs.) per month. Those storage time limitations (180 days maximum) then become applicable when the total quantity of hazardous waste in storage first exceeds 1000 kg.

One-Time Cleanups: For a one-time cleanup that will result in the generation of more than 100 kg. Per month of hazardous wastes or result in more than 1000 kg. of hazardous wastes on site at one time, a CESQG may be eligible for a one-time exemption, which will enable him to keep his CESQG status. State environmental agencies often will make such provision provided the CESQG notifies them ahead of time. Call your local environmental agency office for information.

Note that the requirements described above are applicable to most CESQGs, but others may apply, as well, especially for acutely hazardous wastes. State requirements may vary; call your local environmental agency or ask your GLOBAL Representative for more information.

Reference: 40 CFR 261.5 See also:
Satellite Accumulation / Storage Requirements / Large Quantity Generators / Small Quantity Generators

This summary is offered for the use of GLOBAL customers is intended to answer common questions asked by generators. It does not address all possible regulatory situations and is not meant to constitute legal advice.