Small Quantity Generator (SQG)

Small Quantity Generator status (40 CFR Part 262, Subpart C) occupies the middle tier of RCRA's generator classification system. SQGs may accumulate hazardous waste on-site for up to 270 days (or 180 days if the waste will be shipped less than 200 miles to a TSDF) without a storage permit, but must not exceed 13,228 pounds of hazardous waste on-site at any time. Each container must be labeled with the words "Hazardous Waste," the accumulation start date, and the applicable hazard warnings. SQGs must maintain a basic contingency plan and designate an emergency coordinator, though the requirements are less extensive than those for LQGs.

California imposes additional requirements beyond federal RCRA for SQGs. DTSC requires annual notification updates, California-specific manifest procedures, and the state's tiered permitting system may require SQGs to obtain a conditional authorization or permit by rule for certain activities. The distinction between SQG and LQG status can shift month to month based on waste generation volumes, and generators must track their monthly totals carefully, unknowingly crossing the LQG threshold without upgrading your compliance program creates immediate violations.

BayArea Compliance monitors our clients' monthly hazardous waste generation volumes to maintain accurate generator status classification. For SQG clients, we ensure compliance with the applicable storage time limits, container labeling requirements, contingency planning, and reporting obligations. If your generation patterns indicate a potential shift to LQG status, we proactively upgrade your compliance program before the threshold is crossed, not after an inspector identifies the discrepancy.