Blog

NEW USEPA RE-NOTIFICATION REQUIREMENT FOR SMALL QUANTITY GENERATORS – DUE SEPTEMBER 1, 2021

Posted on August 18th, 2021

Hazardous waste sign on fence with drums

The United States Environmental Protection Agency (USEPA) has enacted new hazardous waste generator requirements to streamline the Resource Conservation and Recovery Act (RCRA) Hazardous Waste requirements and maintain accurate compliance records. According to the new requirements, Small Quantity Generators (SQGs) must re-notify the USEPA of their hazardous waste activities under the November 2016 Hazardous Waste Generator Improvements Rule. Previously, SQGs were not required to routinely submit information about their waste activities after the initial notification unless updates or changes were made.

The deadline for the first re-notification is September 1, 2021 and then every four years thereafter. Notifications for the upcoming September deadline are only required in states where the Hazardous Waste Generator Improvements Rule is already adopted (including New Jersey).

WHAT IS A SMALL QUANTITY GENERATOR?

SQGs generate more than 220 pounds (100 kilograms), but less than 2,200 pounds (1,000 kilograms), of non-acute hazardous waste per calendar month. SQGs also generate less than 2.2 pounds (1 kilogram) of acute hazardous waste per calendar month. For more information on hazardous waste generators, see the USEPA’s website here: Categories of Hazardous Waste Generators.

WHAT IS THE RE-NOTIFICATION PROCESS?

SQG facilities re-notify by electronically submitting the USEPA 8700-12 Site Identification Form using the RCRAInfo online system. This requires a RCRAInfo login and access permissions for each site. Submittal of a Site Identification Form anytime within the four years before the due date will meet the re-notification requirement.

If your facility is a SQG of hazardous waste, JMS can assist you in completing and submitting the USEPA 8700-12 Site Identification Form to satisfy the re-notification requirement. Please contact us at 908-218-0066 or consult@jmsorge.com to learn how we can assist you through the process.

For more information on the SQG re-notification requirements, see the links below.

NJDEP Compliance Advisory Statement

USEPA Memo – Implementing the Small Quantity Generator Re-Notification Requirement from the 2016 Generator Improvements Final Rule

Cassondra Spilatro

Project Manager


Get In Touch