SQG Hazardous Waste Generators Re-Notification Deadline Approaching September 1st, 2025

Under the Hazardous Waste Generator Improvements Rule that became effective May 30, 2017, small-quantity generators (SQGs) of hazardous waste were required to re-notify the EPA using Form 8700-12 by September 1, 2021 and every four years thereafter. This rule was enacted to ensure that the EPA stays up to date if SQGs go out of business, transition ownership, or change their regulatory category. As four years have now passed since that initial re-notification date, SQGs must again re-notify the EPA through the submission of EPA Form 8700-12 by September 1, 2025.

As a refresher, the regulatory requirements of RCRA waste vary based on the volume of hazardous waste generated by a facility in a calendar month. There are three generator categories – large quantity generators (LQG), small quantity generators (SQG), and very small quantity generators (VSQG).

The generator categories are determined as follows:

	Large Quantity Generator (LQG)	Small Quantity Generator (SQG)	Very Small Quantity Generator (VSQG, formerly CSEQG)
Hazardous Waste Quantity Limit	Greater than or equal to 2,220 lb (1,000 kg) per month; greater than 2.2 lb (1 kg) per month of acute hazardous waste; and greater than 220 lb (100 kg) of acute spill residue or soil.	More than 220 lb (100 kg) but less than 2,220 lb (1,000 kg) per month.	Less than or equal to 220 lb (100 kg) per month; less than or equal to 2.2 lb (1 kg) per month of acute hazardous waste; and less than or equal to 220 lb (100 kg) per month of acute spill residue or soil.

In some states, such as Pennsylvania, the re-notification requirement is satisfied by submitting notification to the state regulatory agency.  If you are located in Pennsylvania, the re-notification can be submitted electronically through GreenPort within the ePermitting module. Paper submittals are also an option in most states. If your state has opted in to myRCRAid, the re-notification can be submitted electronically through this system.

Liberty is available to answer any additional questions related to the re-notification requirement or to assist in the re-submittal process.  Questions or requests for assistance can be directed to Katie Cirone, P.E., CHMM, at (800) 305-6019, extension 2500, or at kcirone@libertyenviro.com.

The EPA Form 8700-12 is available here:https://rcrapublic.epa.gov/rcrainfoweb/documents/notification.pdf

Read the EPA’s Re-Notification Requirements posting here: https://www.epa.gov/hwgenerators/re-notification-requirement-small-quantity-generators