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What Regulations Apply to me?

All generators in Vermont are required to determine if their waste is subject to regulation as hazardous waste under the Vermont Hazardous Waste Management Regulations (VHWMR). If you generate hazardous waste in Vermont, you are required to obtain an EPA Identification Number from the Vermont Hazardous Waste Program. Regulatory requirements and generator fees increase with waste generator category, so it is important that generators accurately determine their generator category.

Summary of Regulatory Requirements for Generators

Requirements VSQG SQG LQG
Generation Rates: Less than 220 lbs. of hazarous
waste, or 2.2 lbs. of acutely hazardous
waste per month.
Generates between 220 and 2,200 lbs. 
of hazardous waste and less
than 2.2 lbs. of acutely hazardous waste
per month. 
Greater than 2,200 lbs. of hazardous
waste or 2.2 lbs. of acutely hazardous
waste per month or has more than 13,200 lbs.
of hazardous waste onsite
Subject to Inspection by the Hazardous Waste Program Yes Yes Yes
Accumulation Time          Limits None ≤180days ≤90 days
Storage Minimum storage requirements (under cover, impervious surface, containers closed, and labeled) Full compliance with requirements for tanks and containers Full compliance with requirements for tanks, containers, drip pads, and containment buildings
Waste Disposal Local Solid Waste District or RCRA permitted facility RCRA permitted facility RCRA permitted facility
Manifests Not required. If used, must follow manifest instructions Required Required
Biennial Report Not required Not required Required
Personnel Training Not required Basic training required Training plan and documentation of training required
Contingency Plan Not required Not required Full plan required
Emergency Procedures Not required Must designate emergency coordinator and post SQG Emergency Preparedness Info Must designate emergency coordinator, maintain contingency plan, and follow specific emergency procedures
Facility Closure Not required Not Required Required
Inventory and Weekly Inspection Not required Required  Required
Episodic Generation Available option Available option Not a hazardous waste management option
Required to Renotify Not required Every four (4) years Every two (2) years. Note: Biennial Reporting Satisfies this requirement