Generator Category

Anyone who generates non-household hazardous waste, must determine their generator category. A generator's category is based on the amount of hazardous waste generated each month and may change from month to month. This section sets forth procedures to determine whether a generator is a very small quantity generator, a small quantity generator, or a large quantity generator for a particular month. 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:

Very Small Quantity Generators (VSQGs) -formerly known as Conditionally Exempt Generators (CEGs) 
Small Quantity Generators (SQGs)
Large Quantity Generators (LQGs)

Generator Category  Quantity of Acute Hazardous Waste Generated in a Calendar Month Quantity of non-acute Hazardous Waste Generated in a Calendar Month Quantity of Residues from a Cleanup of Hazardous Waste Generated in a Calendar Month 
Large Quantity Generator > 1 kg (2.2 pounds Any amount Any amount
Large Quantity Generator Any amount ≥ 1,000 kg (2,200 pounds) Any amount
Large Quantity Generator Any amount Any amount ≤ 100 kg (220 pounds)
Small Quantity Generator ≤ 1 kg (2.2 pounds) > 100 kg (220 pounds) and          <1,000 kg (2,200 pounds) ≤ 100 kg (220 pounds)
Very Small Quantity Generator ≤ 1 kg (2.2 pounds) ≤ 100 kg (220 pounds) ≤ 100 kg (220 pounds)

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 Category 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 can be managed under used oil standards (Subchapter 8 of the VHWMR) and universal wastes (i.e., batteries, certain pesticides, mercury thermostats, PCB-containing fluorescent light ballasts, lamps, mercury-containing devices, CRTs and aersol cans) can be managed under alternate standards (Subchapter 9 of the VHWMR), they should not be counted when calculating generator status.

  • For pharmaceutical wastes: a person shall count all hazardous waste except hazardous waste pharmaceuticals that are subject to and managed in accordance with Subchapter 10 of VHWMR.


GENERATOR TREATMENT DEFINITION
“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.

Tags: 

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

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