EPA RCRA Hazardous Waste Generator Requirements in Florida

EPA classifies hazardous waste generators into three categories based on monthly generation quantities. Your category determines your accumulation time limits, labeling requirements, emergency planning obligations, and reporting requirements.

• Very Small Quantity Generator (VSQG): Generates ≤100 kg/month of hazardous waste (≤1 kg/month of acutely hazardous waste) — minimal requirements but must still use licensed treatment, storage, and disposal facilities (TSDFs)
• Small Quantity Generator (SQG): Generates 100–1,000 kg/month — 270-day accumulation limit, must have emergency procedures and contingency plan, annual reporting not required but records must be maintained
• Large Quantity Generator (LQG): Generates >1,000 kg/month — 90-day accumulation limit, full emergency planning and training requirements, biennial reporting to EPA required
• Acutely hazardous waste (P-listed): Even 1 kg/month triggers LQG requirements for that waste stream — common in healthcare settings with P-listed pharmaceuticals

Florida is an EPA-authorized RCRA state, meaning Florida DEP administers the RCRA program under state law (Chapter 62-730, Florida Administrative Code). Florida's program is at least as stringent as federal RCRA and includes some state-specific provisions.

• Florida DEP Registration: Hazardous waste generators must obtain an EPA ID number — Florida generators register through Florida DEP's online portal
• Florida transporter requirements: Hazardous waste must be transported by a DEP-licensed hazardous waste transporter — not just any licensed hauler
• Manifest requirements: All shipments of hazardous waste require a Uniform Hazardous Waste Manifest (EPA Form 8700-22) — electronic manifesting is required through EPA's e-Manifest system
• Land Disposal Restrictions (LDR): Florida enforces LDR requirements — generators must certify their waste meets treatment standards before land disposal
• Annual reporting: Florida LQGs must submit biennial reports; VSQGs and SQGs are exempt from biennial reporting but must maintain records for three years

Florida DEP and EPA Region 4 conduct routine inspections of hazardous waste generators. The following violations appear most frequently in inspection records and enforcement actions:

• Accumulation time limit exceedances — holding hazardous waste beyond the category's time limit without proper interim status
• Missing or improper container labeling — containers must be labeled 'Hazardous Waste' with the waste name, accumulation start date, and generator information
• Improper storage — containers must be in good condition, compatible with contents, kept closed, and stored in secondary containment areas
• Manifest violations — missing signatures, incorrect waste descriptions, or failure to retain manifest copies for three years
• Missing emergency contact information — SQGs and LQGs must post emergency contact information and maintain emergency response equipment
• Unpermitted treatment — treating hazardous waste on-site (neutralizing, blending) without proper permits or exemptions