With the California Department of Toxic Substances Control’s (DTSC) adoption of the U.S. EPA’s Hazardous Waste Generator Improvements Rule (GIR), a new generator category—Very Small Quantity Generator (VSQG)—was formally introduced into California’s hazardous waste regulations. But what does this change actually mean for businesses?
Federal Definition and Requirements for VSQGs
The U.S. EPA has long recognized the VSQG category for facilities that, within a single calendar month, generate:
- ≤ 100 kg of non-acute hazardous waste, and
- ≤ 1 kg of acute hazardous waste.
Compared to Small Quantity Generators (SQGs) and Large Quantity Generators (LQGs), VSQGs under federal regulations are subject to less stringent requirements. These include no specific time limit for waste accumulation, no mandatory personnel training, and no requirement for a formal emergency response plan, among others.
Before July 1, 2024: Only Two Generator Categories
Historically, California recognized only two categories of hazardous waste generators:
- Small Quantity Generators (SQGs): Facilities that generate less than 1,000 kilograms of non-acute hazardous waste and 1 kilogram or less of acutely hazardous or extremely hazardous waste per month.
- Large Quantity Generators (LQGs): Facilities that generate 1,000 kilograms or more of non-acute hazardous waste and more than 1 kilogram of acutely hazardous or extremely hazardous waste per month.
This meant that even facilities generating less than 100 kg of non-acute hazardous waste per month were classified as SQGs and had to comply with SQG-level requirements.
After July 1, 2024: VSQG Defined, But Not Exempt
California’s updated regulations now define VSQGs in 22 CCR §66262.13, aligning with federal thresholds. However, the DTSC did not adopt the federal exemption conditions for VSQGs. As a result, facilities that qualify as VSQGs in California must still comply with SQG-level requirements (22 CCR §66262.16), which include but are not limited to:
- Hazardous waste accumulation limits: No more than 180 days onsite and no more than 6,000 kg at any time.
- Annual Electronic Verification Questionnaire (eVQ) submission.
However, VSQGs are not required to renotify the DTSC using EPA Form 8700-12 every four years, unlike SQGs and LQGs.
So, What’s Changed for Existing VSQG-Level Generators?
In practice, not much has changed for now. Businesses generating VSQG-level quantities of hazardous waste before July 2024 were already subject to SQG regulations. The new definition simply formalizes the VSQG category without offering regulatory relief.
These businesses can continue operating with their State ID number and must maintain compliance with SQG requirements.
The changes to California’s hazardous waste regulations related to a facility’s waste generator status are summarized in the table below.
For more information on updates to California’s hazardous waste management rules, or for help implementing them at your facility, please contact us.
This blog was written by Mutya Cruz, PhD, a Quality, Research, and Training (QRT) Specialist at Safety Partners.
