Small Business Assistance - Permit Primer
Topic - Hazardous Waste
You are a Very Small Quantity Generator (VSQG).
As a Very Small Quantity Generator, there are several procedures, requirements and Best Management Practices or BMPs your business needs to be aware of. Review the following table to determine which requirements apply. In addition we suggest that you review the "Common Violations" fact sheet immediately following the table.
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NOTE: press ALT then F4 to close any pop-up windows - all links found along the right column of table below.
Very Small Quantity Generator Requirements
Issue
|
Required?Yes / No
|
Available Fact Sheet or Web Site
|
Waste Determination | Yes By completing this portion of the Small Business Assistance Web Page you have made a waste determination. If you generate a new waste or make a process change, you need to go through this review. |
What is Hazardous Waste?
(WA-106)
Hazardous Waste Determination: Guide Through NR 605 (WA-204) |
Accumulation Limit | Yes VSQGs must not accumulate more than 2,205 lbs. (total) of hazardous waste at their facility at any time. |
|
Manifest Requirements | No You are not required to manifest your waste shipments but if you should choose to do so (and some disposal facilities may ask for a manifest), you need to obtain an EPA identification number and comply with the manifest requirements. |
Hazardous Waste Manifest (WA-102) |
EPA ID Number | No Obtain an EPA ID Number only if you are manifesting your hazardous waste. |
EPA Identification Number
(WA 101)
|
Container Storage | Yes VSQGs should store waste in accordance with the guidance found in the right column. |
Hazardous Waste Container
Guidance (pdf)
Hazardous Waste Inspection Logs (WA-098) |
Department of Transportation (DOT) Requirements | Yes Package, mark and label your wastes in accordance with the U.S. Department of Transportation's hazardous materials transportation requirements prior to shipping |
Chapter
TRANS 326, Wisc. Adm. Code - Motor Carrier Safety Requirements
for Transporting Hazardous Materials
(Exit DNR) Office of Hazardous Materials Safety - Regulations, Clarifications and Exemptions - Web Page (49 CFR, 100-185) (Exit DNR) Marking and Labeling Per Dept. of Transportation Requirements (Exit DNR) |
Licensed Transporter | Yes Use a WI DNR licensed hazardous waste transporter. NOTE: If you will be transporting the waste yourself, you will need a Hazardous Waste Transporter License. Please Refer to the link along right column. |
Transporting Hazardous
Waste (WA-137)
WI Licensed Commercial Transporters (SW-234) Household and VSQG Collection Facilities (WA-737) Hazardous Waste Transporter - Web Page (Exit DNR) |
Proper Treatment, Storage and Disposal of Your Waste | Yes Properly recycle, treat or dispose of your hazardous waste at a licensed Treatment, Storage and Disposal (TSD) facility. NOTE: If you are a TSD, you will need a TSD license. Please refer to the Hazardous Waste Facility (TSD) link along right margin. |
Recycling Hazardous
Waste: DNR Requirements in Brief: (WA-191)
WI Licensed Commercial TSD's (WA-235) Household and VSQG Collection Facilities (WA-737) Hazardous Waste Facility (TSD) License - Web Page (Exit DNR) |
Land Disposal Restrictions | ||
Safety, Training & Emergency Procedures | No It is recommended, but not required, that you establish emergency procedures for responding to environmental emergencies such as leaks, spills and fires involving hazardous wastes |
Hazardous Waste Training Records (WA-099) |