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Safety

Waste Generator Categories

Under the EPA’s Resource Conservation and Recovery Act (RCRA), not all laboratories are treated equally. The stringency of the regulations a facility must follow depends directly on the quantity of hazardous waste it generates in a calendar month. This tiered system allows smaller entities (like a physician’s office lab) to operate with fewer administrative burdens than massive industrial facilities or large research hospitals. It is critical for a laboratory to determine its “Generator Status” accurately, as operating under the wrong category is a frequent source of substantial EPA fines

Determining Generator Status

Status is determined by measuring the total weight of all hazardous waste generated at the entire site (not just the lab) in a single month. This includes P-listed (acutely toxic) and U-listed (toxic) wastes, as well as characteristic wastes (ignitable, corrosive, reactive, toxic)

  • P-Listed Waste (Acute Hazardous Waste): Chemicals so deadly (e.g., Sodium Azide, Cyanides, Strychnine) that generating even a tiny amount triggers strict regulations
  • Episodic Generation: If a lab usually generates very little waste but does a massive clean-out one month, its status may temporarily “bump up” to a higher category for that month, requiring stricter compliance during that period

The Three Categories

Very Small Quantity Generator (VSQG)

Formerly known as “Conditionally Exempt Small Quantity Generator” (CESQG).

  • Definition: Generates \(\le\) 100 kg (approx. 220 lbs) of hazardous waste per month AND \(\le\) 1 kg (2.2 lbs) of acutely hazardous (P-listed) waste per month
  • Typical Facility: Small physician office laboratories (POLs), small independent clinics
  • Requirements
    • Identification: Must identify all hazardous waste generated
    • Limit: Cannot accumulate more than 1,000 kg of waste on-site at any time
    • Disposal: Must ensure waste is sent to a permitted facility (even a municipal landfill if permitted by the state, though this is rare/unsafe practice; usually sent to a TSDF)
    • No EPA ID: Federal law does not require VSQGs to have an EPA ID number (though many transporters and states require it)
    • Manifest: Not federally required to use a manifest (though highly recommended for liability protection)

Small Quantity Generator (SQG)

  • Definition: Generates between 100 kg and 1,000 kg (220 - 2,200 lbs) of hazardous waste per month
  • Typical Facility: Community hospitals, medium-sized reference laboratories
  • Requirements
    • EPA ID Number: Mandatory
    • Storage Time: Can store waste on-site for up to 180 days (or 270 days if shipping >200 miles) without a storage permit
    • Emergency Coordinator: Must have a designated Emergency Coordinator on-site or on-call at all times
    • Manifests: Required for all shipments
    • Inspections: Must inspect waste storage areas weekly
    • Training: Employees must be “thoroughly familiar” with waste handling procedures (basic training required)

Large Quantity Generator (LQG)

  • Definition: Generates \(\ge\) 1,000 kg (2,200 lbs) of hazardous waste per month OR > 1 kg (2.2 lbs) of acutely hazardous (P-listed) waste per month
  • Typical Facility: Large academic medical centers, major reference labs, research universities
  • Requirements (Most Stringent)
    • EPA ID Number: Mandatory
    • Storage Time: Can store waste on-site for only 90 days. Exceeding this makes the lab a “Storage Facility” requiring an expensive permit
    • Personnel Training: Formal, documented classroom training required annually for all personnel involved in waste management
    • Contingency Plan: Must have a written, detailed contingency plan distributed to local police, fire, and hospitals
    • Biennial Report: Must file a detailed report to the EPA every two years (on even-numbered years) summarizing waste activities
    • Closure Plan: Must have a plan for closing the waste accumulation area if the facility shuts down

Satellite Accumulation Areas (SAA) vs. Central Accumulation Areas (CAA)

Regardless of status, laboratories manage waste in two distinct physical zones

  • Satellite Accumulation Area (SAA)
    • Location: At or near the point of generation (e.g., under the fume hood in the Hematology lab)
    • Control: Under the control of the operator generating the waste
    • Limit: Can accumulate up to 55 gallons of hazardous waste (or 1 quart of acute waste) indefinitely
    • Requirement: Once the container is full, it must be dated and moved to the CAA within 3 days
  • Central Accumulation Area (CAA)
    • Location: The main waste room or loading dock where waste is consolidated before shipping
    • Clock: The “storage clock” (90 or 180 days depending on SQG/LQG status) starts the moment waste arrives here
    • Safety: Must have restricted access, emergency equipment (fire extinguisher, spill kit, phone), and weekly documented inspections checking for leaks or corrosion