Generator Status

The Vermont Hazardous Waste Management Regulations (VHWMR) apply to businesses or non-household waste generators (hazardous waste generators). Household hazardous waste is not regulated under the Hazardous Waste Program. State and federal hazardous waste regulations classify hazardous waste generators into three categories based on the amount of hazardous waste generated each calendar month. In Vermont, these categories are:

Conditionally Exempt Generators (CEGs)
Small Quantity Generators (SQGs)
Large Quantity Generators (LQGs)

Some key considerations when calculating generator status:

  • Exempt wastes do not count toward generator status.  Exempted wastes are listed and discussed in Subchapter 2 of the VHWMR.
  • Generator status is determined based on the amount of hazardous waste generated per month, and not the amount of hazardous waste shipped in a particular month.

  • Any hazardous waste that is reclaimed and subsequently reused on-site only needs to be counted as being generated one time.  Please note that if reclamation involves generator treatment (see definition below), a Generator Treatment Form needs to be completed.   

  • Because used oil and universal wastes (i.e., batteries, certain pesticides, mercury thermostats, PCB-containing fluorescent light ballasts, lamps, mercury-containing devices, and CRTs) are exempt, they should not be counted when calculating generator status.

“Treatment”means any method, technique, or process, including neutralization, designed to change the physical, chemical or biological character or composition of any hazardous or solid waste, so as to neutralize such waste, or so as to recover energy or material resources from the waste, or so as to render such waste safer for transport, amenable for recovery, amenable for storage, or reduced in volume, or for hazardous wastes, so as to render such waste non-hazardous. Examples include but are not limited to: distillation, neutralization, compaction.


Agency of Natural Resources
Department of Environmental Conservation
Waste Management and Prevention Division

Davis Building - 1st Floor
One National Life Drive
Montpelier, VT 05620-3704