RCRA Hazardous Waste Generator Requirements - Ohio

Generator Categories

Your generator category is determined by the total weight of hazardous waste generated at your site during each calendar month. The category determines which rules apply.

Category	Non-Acute Hazardous Waste	Acute Hazardous Waste	Max On-Site Accumulation
VSQG	100 kg or less/month (220 lbs)	1 kg or less/month	1,000 kg at any time
SQG	>100 kg to <1,000 kg/month (220-2,200 lbs)	1 kg or less/month	6,000 kg at any time
LQG	1,000 kg or more/month (2,200+ lbs)	>1 kg/month	No quantity limit (time-limited)

Your generator category can change month to month based on actual generation. If you exceed the thresholds for your current category in any month, you must comply with the requirements of the higher category for that month’s waste.

What Counts Toward Your Monthly Total

Under OAC 3745-52-13, count all hazardous waste that is:

• Accumulated and transported off-site
• Generated as still bottoms or sludges removed from product storage tanks
• Placed directly into a regulated on-site treatment or disposal unit

What Does NOT Count

• Waste already counted once in the same month (no double counting)
• Samples collected to determine if waste is hazardous
• Hazardous waste remaining in empty containers
• Specific recyclable materials (scrap metal managed under recycling exemptions)
• Universal wastes managed under universal waste rules

Accumulation Time Limits

Generators may accumulate hazardous waste on-site without a TSDF permit for the following periods:

Category	Accumulation Limit	Extension
VSQG	No time limit (1,000 kg quantity limit)	N/A
SQG	270 days	N/A (180 days if TSDF is within 200 miles)
LQG	90 days	None

The accumulation start date must be clearly marked on each container. Exceeding the time limit is considered unpermitted storage - one of the most frequently cited and heavily penalized RCRA violations in Ohio.

Satellite Accumulation

Generators may accumulate up to 55 gallons of hazardous waste (or 1 quart of acute hazardous waste) at or near the point of generation under satellite accumulation rules. Once the 55-gallon limit is reached, the generator has 3 days to move the waste to the main accumulation area, and the accumulation clock starts.

Container Management

All generators must:

• Keep containers closed except when adding or removing waste
• Store containers in good condition (no leaking, rusting, or bulging)
• Use containers compatible with the waste stored in them
• Not stack incompatible wastes in the same area
• Inspect containers at least weekly (SQGs and LQGs)

Labeling Requirements

Containers must be labeled with:

• The words “Hazardous Waste”
• An indication of the hazards (using words, pictograms, or DOT hazard labels)
• The date accumulation begins (except for satellite accumulation containers below the 55-gallon threshold)

The Generator Improvements Rule (effective October 5, 2020 in Ohio) strengthened labeling requirements to include hazard indication on all containers, not just those in the main accumulation area.

Manifesting and Transportation

Manifest Requirements

SQGs and LQGs must use the Uniform Hazardous Waste Manifest (EPA Form 8700-22) for all off-site shipments of hazardous waste. The manifest tracks the waste from the generator through transportation to the receiving TSDF.

VSQGs are not federally required to manifest but should verify requirements with their transporter and the receiving facility.

e-Manifest

As of January 2025, all SQGs and LQGs must register with EPA’s e-Manifest system{target=“_blank”}. Generators must upload a copy of the signed final manifest to e-Manifest within 35 days of shipment. LQGs that do not receive a signed copy of the manifest from the TSDF within 35 days must contact the transporter and/or TSDF. If not resolved within 45 days, an exception report must be submitted to Ohio EPA.

Transporter Requirements

Off-site shipments must use a hazardous waste transporter with an EPA ID number. DOT shipping requirements (49 CFR 172-179) apply to all hazardous waste shipments.

VSQG exception: VSQGs consolidating waste at an LQG under the control of the same person may ship without a manifest or registered transporter, provided DOT requirements are met.

Training

LQGs

Must ensure all employees who handle hazardous waste complete initial training within 6 months of employment and annual refresher training thereafter. Training must cover emergency response procedures, waste handling, and container management. Training records must be maintained.

SQGs

Must ensure employees are thoroughly familiar with proper waste handling and emergency procedures relevant to their responsibilities.

VSQGs

No specific training requirements, but should ensure employees handling waste understand basic safety and regulatory requirements.

Emergency Preparedness

LQGs

• Must prepare and maintain a written contingency plan
• Must submit the contingency plan and a quick reference guide to local fire departments, hospitals, police, and local emergency planning committees (LEPCs)
• Must designate an emergency coordinator available at all times
• Must maintain emergency equipment (fire extinguishers, spill control, communications, decontamination)

SQGs

• Must maintain basic emergency equipment
• Must designate an emergency coordinator
• Must post emergency information (name of coordinator, fire department number, location of equipment)
• Must make arrangements with local emergency responders and document the attempt

LQG Closure

Under the Generator Improvements Rule, LQGs must notify Ohio EPA at least 30 days before closing their facility and again within 90 days after closing. The facility must meet the closure performance standards of OAC 3745-52-17(A)(8)(c).

Reporting

Biennial Report (LQGs Only)

LQGs must submit a biennial hazardous waste report to Ohio EPA by March 1 of each even-numbered year. The report covers all hazardous waste generated, managed, and shipped during the previous calendar year. Reports are submitted through the RCRAInfo system.

LQGs must also re-notify Ohio EPA every 2 years (OAC 3745-52-18(D)(2)), which can be satisfied by filing the biennial report.

SQG Re-Notification

SQGs must re-notify Ohio EPA of their status every 4 years using Form 9029.

Episodic Generation

Ohio adopted the federal episodic generation provisions (effective October 5, 2020). VSQGs and SQGs that temporarily exceed their generator category limits due to a non-routine event can maintain their existing category if they:

1. Notify Ohio EPA at least 30 days before a planned event (or within 72 hours of an unplanned event)
2. Obtain an EPA ID number (required for episodic generation even for VSQGs)
3. Comply with specific labeling, accumulation, manifest, and recordkeeping requirements
4. Ship episodic waste within 60 days of the event

One episodic event is allowed per calendar year, with the ability to petition Ohio EPA for a second. If the first event is planned, the second must be unplanned (or vice versa).

Common Violations

Based on Ohio EPA enforcement patterns, the most frequently cited generator violations include:

• Failure to properly label containers (missing “Hazardous Waste” marking, no hazard indication, no accumulation date)
• Exceeding accumulation time limits
• Failure to obtain or maintain an EPA ID number
• Missing or incomplete manifests
• Failure to submit biennial reports on time (LQGs)
• Inadequate employee training records
• Open containers in the accumulation area

Resources

• Ohio EPA Generator Requirements Summary Table (PDF)- Ohio EPA Notification of Regulated Waste Activity{target=“_blank”} - Form 9029
• EPA e-Manifest- Ohio RCRA and Hazardous Waste Program Overview
• Hazardous Waste Determination Guide