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Hazardous Waste Generator Basics (RCRA) for Facility Staff
For facility staff who handle hazardous waste: why waste determinations matter, how generator category sets your limits, and how to manage satellite and central accumulation containers so they stay closed, marked, inspected and safe.
Based on EPA 40 CFR 262.11, 262.13, 262.15, 262.16(b) and 262.17(a) (Standards applicable to generators of hazardous waste) · about 6 min read
Need proof of training? The full course (25 min) adds practice questions, a job scenario, the final quiz and a certificate your employer can verify.
Whoever generates a solid waste must make an accurate determination of whether it is a hazardous waste. Your facility's environmental staff usually make the call, but they rely on what you know about the waste.
Where and when: at the point of generation, before any dilution, mixing or other change, and again any time the waste may have changed its properties.
How: check whether the waste is excluded, whether it is a listed waste, and whether it shows a hazardous characteristic. Knowledge such as the waste's origin, composition and the process that made it can be used.
Records: small and large quantity generators keep records supporting the determination for at least three years from when the waste was last sent for treatment, storage or disposal.
Your part: a good practice is to never pour, mix or dilute a waste to "fix" it. If a new waste stream appears, or a process changes, tell whoever makes the determinations before the waste goes in a container.
Your facility's category is based on the amount of hazardous waste generated each calendar month, and it may change from month to month.
Category
Non-acute hazardous waste per month
Acute hazardous waste per month
Very small (VSQG)
100 kg or less
1 kg or less
Small (SQG)
more than 100 kg and less than 1,000 kg
1 kg or less
Large (LQG)
1,000 kg or more
more than 1 kg
Any one column is enough: more than 1 kg of acute hazardous waste, 1,000 kg or more of non-acute hazardous waste, or more than 100 kg of residues from a cleanup of acute hazardous waste in a calendar month makes a large quantity generator (Table 1 of 40 CFR 262.13). These are the federal thresholds; a state with an authorized program may set more stringent ones, so follow your site's procedures.
What the category means for waste on site
Small quantity generatorAccumulates on site for no more than 180 days (unless an extension condition applies), and never more than 6,000 kg of non-acute or 1 kg of acute hazardous waste.
Large quantity generatorAccumulates on site for no more than 90 days, unless an extension or F006 condition applies.
For small and large quantity generators, a satellite accumulation area is at or near the point where the waste is first made, and under the control of the operator of that process. It may hold up to 55 gallons of non-acute hazardous waste, and/or one quart of liquid or 1 kg of solid acute hazardous waste. The container must be:
In good condition. If it is not in good condition or begins to leak, immediately transfer the waste to a container in good condition that does not leak, or immediately transfer and manage it in the central accumulation area.
Compatible. Made of or lined with material that will not react with the waste. Do not put incompatible wastes in the same container, except as 40 CFR 265.17(b) allows.
Closed at all times, except when adding, removing or consolidating waste, or when temporary venting is necessary for proper equipment operation or to prevent a dangerous situation.
Marked or labeled with the words "Hazardous Waste" and an indication of the hazards of the contents (for example ignitable, corrosive, reactive, toxic).
Over the limit? Within three consecutive calendar days, the excess must be moved to the central accumulation area (or another allowed facility), or the area must meet central accumulation rules. Mark the container with the date the excess began accumulating.
This 5-gallon safety can of spent solvent sits beside a parts washer.
Closed
The container must be closed at all times during accumulation, except when adding, removing or consolidating waste, or when temporary venting is necessary. A funnel left open in the bung does not count as closed. (A good practice: use a self-closing funnel or lid.)
"Hazardous Waste"
The container must be marked or labeled with the words "Hazardous Waste."
Hazard indication
It must also show an indication of the hazards of the contents, such as the characteristic: ignitable, corrosive, reactive or toxic. A DOT label, an OSHA HazCom pictogram, or an NFPA 704 label can also be used.
Compatible and in good condition
The container must be made of or lined with material that will not react with the waste. If it is not in good condition (for example, rusted through) or begins to leak, the waste must be moved immediately to a good container or into the central accumulation area.
In a small or large quantity generator's central accumulation area, containers carry the same "Hazardous Waste" words and hazard indication, plus:
The accumulation start date, clearly visible for inspection on each container. That date starts the 180-day or 90-day clock.
Closed during accumulation, except when it is necessary to add or remove waste, and never opened, handled or stored in a way that may rupture it or cause it to leak.
Separated from incompatible wastes or materials nearby by a dike, berm, wall or other device.
Weekly inspection
At least weekly, the central accumulation area is inspected for leaking containers and for deterioration caused by corrosion or other factors.
At all times, at least one employee on the premises or on call is the emergency coordinator.
Posted next to telephones or in the waste areas: the coordinator's name and emergency number; the location of fire extinguishers, spill control material and any fire alarm; and the fire department's number (unless there is a direct alarm).
All employees must be thoroughly familiar with proper waste handling and emergency procedures relevant to their responsibilities.
Large quantity generators follow the fuller preparedness, prevention and contingency plan rules in Subpart M of Part 262.
Your part: know who the emergency coordinator is and where the spill kit is before you need them.
Fact-checked against the regulation text on October 09, 2026. This certificate records completion of awareness training based on EPA 40 CFR 262.11, 262.13, 262.15, 262.16(b) and 262.17(a). It is not an OSHA card or license, and it is not an EPA or state certification. It does not by itself meet the training requirements of 40 CFR 262.17(a)(7) or 262.16(b)(9)(iii). A large quantity generator must still ensure that facility personnel successfully complete a program of classroom instruction, online training, or on-the-job training, directed by a person trained in hazardous waste management procedures, that teaches them hazardous waste management procedures (including contingency plan implementation) relevant to their positions, within six months after the date of their employment or assignment, and that they take part in an annual review. A small quantity generator must still ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies. States with authorized programs may have more stringent or more extensive requirements.
This guide explains the rule in plain words. Always read the regulation itself and your employer's site-specific procedures.