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August 25, 2021
Hazardous waste SQGs must submit renotification form this September 1
By Elizabeth M Dickinson, JD, Senior Legal Editor - EHS

A new reporting deadline for hazardous waste small quantity generators (SQGs) is fast approaching. Do you know what you need to do?

Hazardous waste large quantity generators (LQGs) have long been accustomed to submitting a biennial Hazardous Waste Report detailing the quantities, types, and management methods of hazardous wastes generated on-site and hazardous wastes received from off-site sources. 

Conversely, hazardous waste SQGs have never had to produce and file any Resource Conservation and Recovery Act (RCRA)-mandated reports. But that changed with the finalization of the Hazardous Waste Generator Improvements Rule (Generator Rule) a few years ago, which currently is in effect in the majority of the states .

SQG renotification

Of immediate concern to SQGs is a requirement that they “renotify” the U.S. Environmental Protection Agency (EPA) (or an authorized state hazardous waste management program) every 4 years. The first renotification submission is due September 1, 2021, and must be submitted on EPA Form 8700-12 , the same form originally filed by all generators to notify the EPA of a generator’s hazardous waste activities. After it’s filed on September 1, 2021, you have until September 1, 2025, before it has to be filed again, unless your state program has more frequent reporting/notification requirements.

Other SQG reports

There are other new EPA filings of which SQGs should be aware. Regarding the Biennial Report that’s due on March 1, 2022, facilities that recycle regulated hazardous waste without first storing the waste (i.e., the facilities do not have a RCRA Part B storage permit) must file a Biennial Report for calendar year 2021. Such facilities could include SQGs that would be otherwise exempt from filing a Biennial Report.

In addition, the Generator Rule also requires an SQG or a very small quantity generator (VSQG) to submit at least one of the four forms that comprise the Biennial Report in circumstances in which the SQG or VSQG generates hazardous waste from an episodic event.

Deadlines coming quickly

These potential Biennial Report filings are in an SQG’s not-too-distant future. But SQG renotification is just around the corner.

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