What’s up with all these acronyms ending in QG?
In the hazardous waste world, these acronyms are short for your hazardous waste generator status.
LQG – Large Quantity Generator
SQG – Small Quantity Generator
VSQG – Very Small Quantity Generator
CESQG – Conditionally Exempt Small Quantity Generator
MQG – Medium Quantity Generator
KSQG – Kansas Small Quantity Generator
These all start at the Federal Level with the EPA, but many states add their own take. From the Federal EPA perspective – we have LQG, SQG, and VSQG. Some states use different acronyms for hazardous waste generator status. For example, Washington State uses MQG to refer to Medium Quantity Generators (which is the equivalent of the EPA’s SQG). Kansas uses KSQG to refer to the Kansas Small Quantity Generator (which is not equivalent to an EPA Generator Status, but for which Kansas has its own definition).
It’s important to know just how important it is to track your actual generation rate for hazardous waste. These generator statuses are based predominantly on how much hazardous waste you generate (create) in any one month. They can also be based on how much total waste you have onsite at any one time, but I would like to talk about tracking your generation rate right now. While conducting a hazardous waste inspection, many inspectors will look through your manifests. If they see a larger volume of hazardous waste being shipped offsite on one particular manifest, they often assume you are a larger quantity generator than you actually are. Remember, the status is based on your generation rate (how much you generate in any one month). So, for example, if an inspector sees a manifest that shows 5,800 pounds of hazardous waste was shipped offsite at one time, they might assume you are a large quantity generator. But, if you can show the inspector that the previous hazardous waste pick-up occurred three months earlier and that it took you three months to accumulate that 5,800 pounds of hazardous waste, you can argue that you generated less than 2,200 pounds per month. Even better, showing the inspector a tracking log where you track the amount of hazardous waste you have onsite (for example, as part of your weekly hazardous waste inspections) could prove your actual generator status. That is why we recommend maintaining a hazardous waste tracking log. This can easily be combined with your weekly hazardous waste inspections. For example:
|Date of Inspection/ Initials||Containers Closed/in Good Condition||Adequate Aisle Space||Accumulation Times Okay||ER Eqpt Operable||Incompatible Separated||Total Amount of Waste|
Corrective Actions: _____________________________________________