Division of Environmental Quality Director: Kyra Moore
Hazardous waste generators are businesses or individuals that produce some form of hazardous waste as a result of their processes. These businesses must follow certain federal and state laws and regulations. The laws and regulations applying to those businesses depend on the amount and type of hazardous waste generated.
Generator Categories
A business determines its hazardous waste generator status using the table below. The highest level the business or individual falls under in any single column determines the appropriate generator status.
| Amount of Acute Hazardous Waste Generated in One Calendar Month | Amount of Acute Hazardous Waste Accumulated at Any One Time | Amount of Residue or Contaminated Soil from a Cleanup of Acute Hazardous Waste Generated in a Calendar Month | Amount of Hazardous Waste Generated in One Calendar Month | Amount of Hazardous Waste Accumulated at Any One Time | |
|---|---|---|---|---|---|
| Large Quantity Generator (LQG) | >1 kg | >1 kg | > 100 kg | ≥ 1,000 kg | ≥ 6,000 kg |
| Small Quantity Generator (SQG) | ≤1 kg | <1 kg | ≤100 kg | >100 kg and < 1,000 kg | <6,000 kg |
| Very Small Quantity Generator (VSQG) | ≤1 kg | <1 kg | <100 kg | ≤100 kg | ≤100 kg |
- 1 kilograms (kg) = Approximately 2.2 pounds
- 100 kg = Approximately 220 pounds
- 1,000 kg = Approximately 2,200 pounds
- 6,000 kg = Approximately 13,200 pounds
A business’ acute hazardous waste cannot be managed separately from other hazardous wastes. For example: LQG status cannot be maintained for acute waste and then maintain SQG status for all other hazardous wastes. Failing to meet any single criteria noted in a generator category above will cause the facility to fall into one of the larger generation categories. For example: even if a facility generates less than 100 kg in a calendar month, if an amount greater than that is accumulated on site this facility is no longer considered VSQG.
Inspectors may check hazardous waste records to make sure a business is classified in the correct hazardous waste generator category and is following the regulations for that category.
Generator Registration
Businesses or individuals generating or accumulating greater than 100 kg of hazardous waste, or 1 kg or more of acutely hazardous waste, are required to register with the Missouri Department of Natural Resources. Those that fall into the very small quantity generator status are not required to register, but may if they choose. If an operation is conducted at more than one location within a city, county or state, each individual site producing hazardous waste will require a separate registration.
Change in Generator Status
According to 10 CSR 25-5.262 (2)(A)3.B., businesses generating or accumulating greater than 100 kg of hazardous waste, or 1 kg or more of acutely hazardous waste, are also required to complete and file an updated Notification of Regulated Waste Activity (NORWA) form whenever there is any change in:
- Contact person
- Mailing address or billing address
- Phone number or area code
- Business name
- Ownership
- Waste stream(s)
- Generator status, including Episodic Events
- Proper street address
- Satellite accumulation option choice
As a convenience to the generator for items 1-3 in the list above, the generator may inform the department of these changes by email or by indicating them in section B of the Generator’s Hazardous Waste Summary Report MO 780-1097. All other changes require completing the NORWA in its entirety.
For a change in ownership, businesses must pay the usual registration fee. If the proper street address changes, such as when a town renames a street or alters numbering on a block, the business will keep its original generator identification number. If a business changes locations, it will need to register the new location and request a new generator identification number using the NORWA. The old generator identification number is not transferable.
Episodic Generators
Many businesses experience a one-time hazardous waste generation event where they produce more hazardous waste than their current generator status. This event could be caused by a change in product line, production error, product recall, spill cleanup, inventory clean-out or similar event. When this occurs and a VSQG either generates or stores over 100 kg (approx. 220 pounds) of hazardous waste, then its generator status changes. The business is required to register as either a SQG or LQG, depending on how much hazardous waste was generated or stored. The business must also follow the regulations for that generator category including submitting a Generator’s Hazardous Waste Summary Report MO 780-1097. After the one time generation event, the business can choose to return to their VSQG status, as long as they no longer generate or accumulate at the higher level. However, hazardous waste fees will apply to the waste generated during the event.
When this type of event occurs at a SQG, the event can be considered an episodic event if it occurs only once in 12 months and the business does not store the extra waste for more than 30 days. Because the situation is temporary, the department considers the business to be in episodic generator status. There are three things to keep in mind when trying to decide if your business qualifies as an episodic generator:
- Amount of hazardous waste currently at the business
- Amount of hazardous waste the business has produced in the past
- Amount of hazardous waste the business plans to produce in the foreseeable future
Send notification by submitting an updated NORWA to the department's Waste Management Program, checking and dating the episodic generation Section VII.A.1.e. on the second page of the form. Be sure to include all of the following additional information, either in the comment section of the NORWA or in a cover letter accompanying the form:
- An updated NORWA
- Reason for the extra hazardous waste
- Estimated amount of extra waste
- Anticipated time period for the event
- A statement saying at the end of the period the business will return to Small Quantity Generator status
If a business notifies the department of its episodic event immediately, it may continue to provide an annual Generator Summary Report. However, it is required to submit a biennial report to the U.S. Environmental Protection Agency if the event occurs in an odd numbered calendar year. For more information on biennial reporting, contact the department’s Waste Management Program at 573-751-3176.
Business operations can be simplified by remaining classified as a LQG if the business believes it will repeatedly cross the limit between SQG and LQG.
Example Episodic Generator
A VSQG performs a one-time clean out of its maintenance shed. One hundred kg of hazardous waste is produced as a result of the clean out. The business must register as a SQG with the department, provide the required hazardous waste reporting and pay the associated fees. The business must follow all SQG requirements while the waste remains on site. The business can return to VSQG status after the waste is transported and as long as they do not produce 100 kg or more in any one calendar month during the next 12 months or accumulate this amount at any one time. The VSQG must also notify the department of its desire to return to VSQG status. This request may be included in a cover letter when submitting their summary report.
Additional Information
Nothing in this document may be used to implement any enforcement action or levy any penalty unless promulgated by rule under chapter 536 or authorized by statute.