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The first re-notification submission deadline for small quantity generators (SQGs) of hazardous waste is quickly approaching, on Sept. 1. The requirement was finalized by the 2016 Hazardous Waste Generator Improvements Rule that stated all SQGs of hazardous waste had to re-notify the EPA every four years. Here’s a snapshot of what you need to know.

Who: EPA defines small quantity generators (SQGs) as those facilities generating more than 100 kilograms but less than 1,000 kilograms of hazardous waste per month.

What: SQGs must re-notify EPA or their state environmental agency by completing and submitting EPA Form 8700-12 or state equivalent. The paper form can be submitted by mail and, in some states, can be submitted via the MyRCRAID system.

Where: This re-notification requirement is currently effective for SQG facilities in authorized states that have adopted the Generator Improvements Rule, as well as states that have been authorized by EPA or where the hazardous waste program is administered by an EPA Region.

When: The first re-notification is due by Sept. 1 and then every four years thereafter, with the next deadline Sept. 1, 2025, unless your state program has more frequent reporting or notification requirements.

Why: EPA created the re-notification requirements to increase the accuracy of its database by identifying SQGs that are active and removing inactive SQGs.

“The first re-notification deadline for small quantity generators of hazardous waste is right around the corner, on September 1.”

Meghan Krishnayya, Compliance & Permitting Service Line Director

About the experts

Meghan Krishnayya, Indianapolis, is the Compliance & Permitting Service Line Director for Brown and Caldwell, with expertise in environmental regulatory program strategy development and implementation.

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