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4.3.2 Small Quantity Generator

By regulation, facilities are categorized as Small Quantity Generators (SQG) if:

  • Facility generates ≤ 100 kilograms and no more than 1000 kilograms (2200 pounds) of hazardous waste in any calendar month.
  • Onsite accumulation time does not exceed 180 days.
  • No more than 1 kilogram (2.2 pounds) per month of acute waste is generated.
  • Total onsite accumulation cannot exceed more than 6,000 kilograms (13,200 pounds).
Note: If the onsite accumulation exceeds 6,000 kilograms, the facility is considered a Treatment Storage and Disposal Facility (TSDF) and must have an approved permit.). SQGs are required to have one emergency coordinator who is either on the premises or on call.

SQG Container Management

Containers of hazardous waste generated in any accumulation area at Cornell should comply with the following requirements:

  • Use of the original chemical product container for hazardous waste storage is a good management practice. Cornell University does not allow hazardous waste to be stored in containers that previously held household products such as bleach, detergents, or any food products.
  • It is not permitted to put the following types of solid materials into containers of liquid hazardous waste: pipettes, magnetic stirrers, vials, test tubes, filters, pH paper.
  • Personnel generating hazardous waste must make a conscious effort to prevent chemical contamination of exterior surfaces of waste containers.

Additionally, the following are state and federal regulatory requirements for the management of hazardous waste containers:

  • Containers must be compatible with the waste in them.

  • Containers must be kept closed except when waste is actually being added.
  • Containers must not be leaking, bulging, rusting, damaged, or dented.

 Go to Section 7.7 for information on management of empty containers.

180-Day Container Storage

  • Containers of hazardous waste must be marked with the date accumulation began, the words HAZARDOUS WASTE, and with other words that identify the contents of the containers. NOTE: The start date is when the first waste is poured / placed into the waste container at the 180-day accumulation point OR the date when the filled container is moved from the satellite accumulation point to the 180-day central storage area. If more than 55 gallons of waste is generated at a satellite area, the excess of 55 gallons must be dated and moved to the 180-day central storage within 72 hours.

  • Weekly inspections must be conducted at 180-day storage area.
  • There must be sufficient aisle space to allow unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area of the operation.
  • Required equipment is easily accessible and in working condition and is tested to ensure it is in working condition.
  • There is internal communications or alarm system capable of providing immediate emergency instruction to personnel.
  • There is a telephone or hand-held two-way radio capable of contacting local and emergency responders.
  • There are portable fire extinguishers and fire control equipment, including special extinguishing equipment (foam, inert gas, or dry chemicals).
  • There is spill control equipment.
  • There is decontamination equipment.
  • There are fire hydrants or other source of water (reservoir, storage tank, etc.) with adequate volume and pressure, foam producing equipment, automatic sprinklers, or water spray systems.
  • When waste leaves the 180-day storage area, it either is going for disposal, treatment, or recycling.
  • No Smoking signs must be conspicuously placed wherever there is a hazard from ignitable or reactive waste.


Personnel must be thoroughly familiar with waste handling and emergency procedures relevant to their responsibilities during normal facility operation and emergencies.


  • SQGs must have an EPA identification number.

  • SQGs must use Uniform Hazardous Waste Manifests when sending waste offsite for disposal or recycling.
  • SQGs must maintain a copy of each signed manifest for 3 years or until the SQG receives a signed copy from the designated facility which received the waste. The returned signed copy is retained as a record for at least 3 years from the date the waste was accepted by the initial transporter.
  • SQGs are required to keep records of waste analyses, tests, and waste determinations for 3 years.
  • Emergency information must be posted by the phone.
  • If the waste being disposed of is restricted from land disposal, the manifest files should contain a copy of the Land Disposal Restrictions (LDR) notice.
  • Documentation of weekly inspections of the 180 storage area.