RCRA Hazardous Waste (US federal)
A list of checks and obligations with their cadence, ready to add to your agenda.
For US businesses that generate hazardous waste under RCRA (40 CFR 262): waste determination, generator category (VSQG/SQG/LQG), e-Manifest, accumulation limits, weekly inspections, personnel training, contingency planning and the biennial report. It does not cover permitted TSDF standards (40 CFR 264/265), wastewater, air emissions, radioactive or medical waste. Note: most states run their own EPA-authorized RCRA programmes that are often stricter than the federal floor; this kit is the federal baseline only and must be supplemented with state and local rules.
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Ask what is in the manuals, how often the maintenance is due and what it takes to do it.
What it already has at hand
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- 14 planned checks, the most frequent every 3 months from installation
Planned checks
Informative summary verified on 12/09/2026. It does not replace legal advice: the regulation cited prevails. If you spot an error, report it.
Some checks are only mandatory in certain countries: pick yours and the list follows.
In Italy this product has no planned checks: the ones listed apply to other countries.
In France this product has no planned checks: the ones listed apply to other countries.
In Germany this product has no planned checks: the ones listed apply to other countries.
In Switzerland this product has no planned checks: the ones listed apply to other countries.
In Austria this product has no planned checks: the ones listed apply to other countries.
In United Kingdom this product has no planned checks: the ones listed apply to other countries.
In Spain this product has no planned checks: the ones listed apply to other countries.
In Portugal this product has no planned checks: the ones listed apply to other countries.
- 01
File the Biennial Hazardous Waste Report
LQGs file the Biennial Hazardous Waste Report by March 1 of every even-numbered year, covering waste generated in the preceding odd-numbered year, on EPA Form 8700-13A/B, with the authorized state agency or the EPA Region. Proof is the RCRAInfo submission receipt or the stamped form, kept for at least 3 years from the report due date. Applies to sites that were LQGs in even a single month of the reporting year; several states require the report from SQGs too, or every year instead of every two.
- 02
Review and update the contingency plan
The LQG must maintain a contingency plan and its Quick Reference Guide and amend them immediately when the applicable regulations, the site layout or processes, the emergency coordinator list or the emergency equipment list change, or when the plan has failed in an emergency; arrangements with local responders and the submission to the LEPC must be kept current too. 40 CFR 262.263 sets no numeric cadence: the annual check proposed here is good practice for catching changes, not a legal deadline. Applies to LQGs: SQGs follow simplified emergency procedures (40 CFR 262.16(b)(8)-(9)) with no federally mandated written plan.
continuous check, confirm every 12 monthsLegal obligation40 CFR 262.263 (amendment of contingency plan); 40 CFR 262.261 (content); 40 CFR 262.262 (quick reference guide); 40 CFR 262.17(a)(6)United States onlySourceverified on 11/09/2026 - 03
Inspect central accumulation areas every week
At least weekly, the staff appointed by the LQG or SQG must inspect central accumulation areas for leaks and for container deterioration caused by corrosion or other factors. Proof is the signed and dated inspection log, kept for 3 years; tanks and tank areas carry additional daily checks. Applies to LQGs and SQGs: there is no federal inspection duty for VSQGs.
continuous checkLegal obligation40 CFR 262.17(a)(1)(v); 40 CFR 262.16(b)(2)(iv)United States onlySourceverified on 11/09/2026 - 04
Make a hazardous waste determination for every waste
For every solid waste generated, the generator must determine at the point of generation, before any dilution or mixing, whether the waste is hazardous, using exclusions, listings, characteristics, testing or process knowledge. Proof is the analytical reports, the methods used and documented process knowledge, kept for at least 3 years from the date the waste was sent for treatment, storage or disposal. Applies to all generators, including VSQGs.
- 05
Re-notify as a Small Quantity Generator on EPA Form 8700-12
Small Quantity Generators must re-notify EPA or the authorized state of their generator activity on EPA Form 8700-12, every four years starting in 2021, by September 1 of the due year (2025, 2029, 2033). Proof is the myRCRAid submission receipt or the state-stamped form. Applies to Small Quantity Generators only: LQGs re-notify through the Biennial Report and VSQGs have no federal notification duty, although many states impose one.
every 4 years by 1 SeptemberLegal obligation40 CFR 262.18(d)United States onlySourceverified on 11/09/2026 - 06
Respect the 180-day accumulation limit (SQG)
A Small Quantity Generator may accumulate hazardous waste on site for no more than 180 days, rising to 270 days if the receiving facility is over 200 miles away, and may never hold more than 6,000 kg of non-acute or 1 kg of acute hazardous waste. The person in charge dates the containers and has them shipped within the limit; proof is the dated labels and the shipping manifests. Applies to Small Quantity Generators only.
every 6 months from installationLegal obligation40 CFR 262.16(b), (c)United States onlySourceverified on 11/09/2026 - 07
Issue and keep an e-Manifest for every shipment
Every off-site shipment of hazardous waste must travel with the Uniform Hazardous Waste Manifest (EPA Form 8700-22), signed by the generator and the transporter and closed out in EPA's e-Manifest system by the receiving facility. The generator keeps the designated-facility-signed copy and the LDR notification for at least 3 years from acceptance by the initial transporter, and files an Exception Report if the signed copy does not come back within 45 days (LQG) or 60 days (SQG). Applies to SQGs and LQGs for every off-site shipment; VSQGs may use alternative channels without a federal manifest where the state allows it.
continuous checkLegal obligation40 CFR 262 subpart B; 40 CFR 262.40(a)United States onlySourceverified on 11/09/2026 - 08
Run the annual RCRA training review (LQG)
LQG personnel handling hazardous waste must complete initial training within six months of hire or assignment and take part every 12 months in a review of that initial training. The employer keeps job descriptions, the training programme and attendance records. Applies as a formal annual duty to LQGs only: SQGs must ensure staff are familiar with proper handling and emergency procedures (40 CFR 262.16(b)(9)(iii)) without any federal numeric cadence.
every 12 months since the last jobLegal obligation40 CFR 262.17(a)(7)(ii), (iii)United States onlySourceverified on 11/09/2026 - 09
Respect the 90-day accumulation limit (LQG)
A Large Quantity Generator may accumulate hazardous waste on site for no more than 90 days without a storage permit. The person in charge of the accumulation area marks every container with the accumulation start date and has it shipped within the limit; proof is the dated labels and the shipping manifests. Applies to Large Quantity Generators only: the Regional Administrator may grant an extension of up to 30 days for unforeseeable circumstances.
every 3 months from installationLegal obligation40 CFR 262.17(a)United States onlySourceverified on 11/09/2026 - 10
Discarded extinguishers are not universal waste
The federal universal waste categories are four — batteries, pesticides, mercury-containing equipment and lamps — and fire extinguishers are not among them, so they cannot be handled under the simplified Part 273 rules. Whoever discards an extinguisher, at end of life or after a failed hydrostatic test, remains an RCRA generator and must make a waste determination before handing it over, looking at both the extinguishing agent and the pressurised cylinder. The workable routes are a maintenance and recharge service or a contractor licensed for hazardous waste and compressed gases; states running their own programme, such as California, may be stricter.
continuous checkLegal obligation40 CFR 273.2 (categorie di universal waste); 40 CFR 262.11 (hazardous waste determination)United States onlySourceverified on 12/09/2026 - 11
Safety device batteries as universal waste
Batteries coming out of the building’s safety devices — defibrillators, emergency lighting units, detectors, uninterruptible power supplies — fall under the general "battery" category of federal universal waste, along with batteries from any other source. Management is the simplified one: no manifest, but a container labelled with the accumulation start date, a one-year limit, protection against short circuits and delivery to an authorised destination facility or recycler. The party that collects them answers as the handler; many states run their own programmes, stricter than the federal baseline.
continuous checkLegal obligation40 CFR 273.2; 40 CFR 273.9 (definizione di "battery")United States onlySourceverified on 12/09/2026 - 12
Count monthly quantities and confirm the generator category
Each calendar month the environmental manager totals the hazardous waste generated and determines the site's category (VSQG, SQG, LQG). Exceeding a threshold in even one month triggers the higher category's duties, episodic generation aside; proof is the monthly quantity log. Applies to every site that generates hazardous waste.
continuous check, confirm every 1 monthsLegal obligation40 CFR 262.13United States onlySourceverified on 11/09/2026 - 13
Mercury-containing equipment: keep it out of ordinary waste
Thermostats, switches, gauges and instruments with a mercury ampoule are one of the four federal universal waste categories: they are collected separately, in closed and sturdy containers that prevent breakage and release, and never go into ordinary refuse or landfill. What triggers this rule is the replacement or removal of the component, typically during work on ageing plant. Whether a given component actually contains mercury has to be checked case by case against the manufacturer’s documentation: for heating equipment this kit cannot state it as a general fact.
continuous checkLegal obligation40 CFR 273.2 (mercury-containing equipment); 40 CFR 273.13(c), 273.33(c)United States onlySourceverified on 12/09/2026 - 14
Ship universal waste within one year of accumulation
Universal waste handlers (lamps, batteries, mercury-containing equipment and thermostats, pesticides, aerosol cans) may accumulate for at most 12 months from the date the waste was generated or received from another handler. The handler must be able to demonstrate that date through labels, inventory or a dedicated area, and keeps the shipping record. Applies to Small and Large Quantity Handlers of Universal Waste; Large Quantity Handlers, above 5,000 kg accumulated, must also notify EPA and keep shipment records for 3 years.
every 12 months from installationLegal obligation40 CFR 273.15; 40 CFR 273.35United States onlySourceverified on 11/09/2026
In Other country this product has no planned checks: the ones listed apply to other countries.
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