RCRA Generator Status Calculator

Enter your monthly hazardous waste quantities. Get your RCRA generator category (VSQG, SQG, or LQG) with storage limits, accumulation time, training requirements, and manifest rules under 40 CFR 262.

Enter Monthly Generation Quantities

Generator status is determined by the highest month of waste generation in any calendar month. Include all waste streams at your facility. Convert gallons to pounds using specific gravity if needed (water = 8.34 lb/gal).

All D, F, K, and U-listed waste combined. Exclude acutely hazardous (P) waste.
Any waste with P-list code. Examples: warfarin, cyanides, aldrin.
Soil, debris, or cleanup material contaminated with P-listed waste.
Leave as 1.0 for water-like wastes. Use SDS value for solvents.

Your Storage & Accumulation Limits

Your Compliance Requirements

    How the Categories Compare

    Category Waste/month Max on-site Accumulation EPA ID Manifest
    VSQG ≤100 kg 1000 kg No limit Not required* Not required*
    SQG 100-1000 kg 6000 kg 180 days Required Required
    LQG >1000 kg No limit 90 days Required Required

    *Some states require VSQGs to have an EPA ID and use manifests. Check your state program.

    State programs can be stricter. California, Massachusetts, Michigan, New Jersey, and several other authorized states have lower generator thresholds or additional requirements. Always verify with your state environmental agency before relying on federal limits alone.

    Understanding Your Category

    How generator status is determined

    Your category is set by the single highest month of waste generation in any calendar month, not an annual average. Generate 500 kg in January and 50 kg every other month, and you are an SQG, not a VSQG. This is called episodic generation when it occurs rarely (see below).

    What counts toward your total

    Include all D, F, K, P, and U-listed waste generated at the site. Exclude waste stored in satellite accumulation areas until it moves to the main accumulation area or the 55-gallon cap is exceeded. Exclude universal waste (batteries, lamps, pesticides, mercury devices) tracked separately. Exclude used oil unless it exhibits a characteristic.

    Episodic generation provision

    Under the 2016 Generator Improvements Rule, VSQGs and SQGs can have one planned or unplanned episodic generation event per calendar year without changing category. Notify EPA via Form 8700-12 at least 30 days before a planned event or within 72 hours of an unplanned event. The event cannot exceed 60 days of waste generation.

    Consolidation from VSQGs to LQGs

    An LQG under common ownership or control with VSQGs can receive waste from those VSQGs under 40 CFR 262.17(f). This is useful for companies with multiple small facilities. The receiving LQG must notify EPA, maintain records, and comply with all LQG requirements for the consolidated waste.

    What if you have zero waste some months?

    Generator status applies only to months in which waste is generated. A facility that generates 500 kg in February and nothing for the rest of the year is an SQG for February and a VSQG (or non-generator) the other months. Reporting and manifesting requirements apply per the status at the time of generation and shipment.

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