CESQG vs. SQG vs. LQG: What’s the Difference?

Are you a generator of hazardous waste? If so, have you ever wondered what the Environmental Protection Agency (EPA) standards are for the amount of hazardous waste you handle?

The EPA has three distinct categories for generators of hazardous waste, each category being differentiated by the amount of waste that a generator produces or manages.

According to the EPA, the three categories of hazardous waste generators (and the regulations for these generator classifications) are as follows:

Conditionally Exempt Small Quantity Generators (CESQG)

• CESQGs generate 100 kilograms or less of hazardous waste per month, or 1 kilogram or less per month of acutely hazardous (highly toxic) waste;

• They must not accumulate above 1,000 kilograms of waste at any period of time;

• CESQGs must identify all generated hazardous waste; and

• CESQGs must ensure, along with all other generators, that the hazardous waste they send off-premises is delivered to a company, landfill, or treatment, storage, and disposal facility (TSDF) that is expressly permitted to handle it.

Small Quantity Generators (SQG)

• SQGs generate in between 100 kilograms and 1,000 kilograms per month;

• A SQG’s quantity of hazardous waste held on-site can never exceed 6,000 kilograms;

• They may accumulate waste, without a permit, on-site for up to 180 days (and up to 270 days if shipping the hazardous waste over a distance that exceeds 200 miles); and

• SQGS must always have at least one employee who acts in an emergency coordinator capacity, available at all times in case of an emergency. Written contingency plans, with detailed response measures, must be readied by SQGs beforehand for handling such emergencies.

Large Quantity Generators (LQG)

• LQGs generate more than a 1,000 kilograms of hazardous waste per month, or more than 1 kilogram per month of highly-toxic or acutely toxic hazardous waste;

• LQGs have no limit on the amount of hazardous waste they may accumulate on site;

• LQGs may only store or accumulate waste on site for a period of 90 days, although some exceptions may apply;

• LQGs must submit a biennial hazardous waste report every two years; and

• LQGs must also always have at least one employee acting in an emergency coordinator capacity in case of an emergency. They also must have written contingency plans with detailed response measures ready beforehand for handling any emergencies.

Please also note that while these federal classifications hold true for most states, some have their own set limits on the amount of waste that a generator may produce or store that may differ from or conflict with EPA requirements and categories. You can find your state’s waste quantity limits on this list provided by the EPA.

Some specific states may even have wholly discrete categories along with regulations which make up these definitions. For example, Massachusetts has what they refer to as a Very Small Quantity Generator (VSQG) classification, which can be thought of as fitting in between the federal definition of a Conditionally Exempt Small Quantity Generator (CESQG) and a Small Quantity Generator (SQG). Accordingly, each state may have their own stipulations on storage and transportation requirements as well.

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