Protecting Public Health and the Environment.

How to Determine Your Generator Status

Every business in Idaho is required to track the volume of wastes generated, determine whether or not each type of waste is hazardous, and ensure that all wastes are properly disposed of according to federal, state, and local requirements.

Calculating How Much Hazardous Waste You Produce

Hazardous waste generators are regulated according to the amount of waste generated in a calendar month. To determine your generator status, calculate how much hazardous waste you produce as follows:

  1. Make a list of wastes you generate.
  2. Identify whether the wastes are a hazardous or non-hazardous. Some resources to help with this determination include:
    • Material Safety Data Sheets
    • Product suppliers
    • EPA and DEQ
    • Analytical testing labs
  3. Add up the total weight of hazardous wastes generated each month. (You may need to convert volume into pounds by using the density of the specific liquid.)

Do you have a sump pump?

If so, you must determine whether the sump waste you generate is hazardous and, if so, include in your hazardous waste volumes.

Do you use solvents?

If so, you must determine whether the spent solvents you generate are hazardous and, if so, include in your hazardous waste volumes.

Generator Categories

Based on volume, hazardous waste generators are classified in one of the three following categories:

  • Conditionally Exempt Small Quantity Generator
  • Small Quantity Generator
  • Large Quantity Generator

Conditionally Exempt Small Quantity Generator (CESQG)

You are a CESQG if you generate:

  • 220 pounds or less of hazardous wastes per calendar month
  • 2.2 pounds or less of acutely hazardous wastes per calendar month

As a CESQG, you are required to:

  • Keep track of your waste by identifying all hazardous wastes generated and determining the total amount generated and stored on-site each month. Be prepared to document that you are within the limits for this classification. You are not required, but may wish, to obtain an EPA Identification Number to track quantities, types, and movement of hazardous wastes you generate.
  • Limit on-site storage of hazardous wastes you generate to no more than 2,200 lbs. at any time.
  • Properly dispose of hazardous wastes. Ensure that all hazardous wastes are delivered to an approved municipal solid waste landfill or permitted hazardous waste facility, or a facility that beneficially uses or reuses, or legitimately recycles or reclaims the waste.

Small Quantity Generator (SQG)

You are an SQG if you generate:

  • more than 220 but less than 2,200 pounds of hazardous wastes per calendar month
  • 2.2 pounds or less of acutely hazardous wastes per calendar month

As an SQG, you are required to:

  • Keep track of your waste by identifying all hazardous wastes generated and determining the total amount generated and stored on-site each month.
  • Obtain an EPA Identification Number to track quantities, types, and movement of hazardous wastes you generate.
  • Limit on-site storage of hazardous wastes you generate to no more than 13,200 lbs. for 180 days or less (or 270 days if treatment, storage, and disposal facility is more than 200 miles from generator facility). (If you store hazardous wastes longer than the regulated time or accept hazardous waste generated by another entity, you may be considered a treatment, storage, and disposal (TSD) facility subject to TSD permitting requirements.)
  • Properly dispose of hazardous wastes. Ensure that all hazardous wastes are delivered to a permitted hazardous waste facility, or a facility that beneficially uses or reuses, or legitimately recycles or reclaims the waste.
  • Report annually to DEQ on the types and quantities of hazardous waste generated and how or where the hazardous waste was stored, treated, or disposed. Link to state reporting form and instructions.

 Large Quantity Generator (LQG)

You are an LQG if you generate:

  • 2,200 or more pounds of hazardous wastes per calendar month
  • more than 2.2 pounds acutely hazardous wastes per calendar month

As an LQG, you are required to:

  • Keep track of your waste by identifying all hazardous wastes generated and determining the total amount generated and stored on-site each month.
  • Obtain an EPA Identification Number to track quantities, types, and movement of hazardous wastes you generate.
  • Limit on-site storage of hazardous wastes you generate to no more than 2.2 lbs. of acutely hazardous wastes for 90 days or less. (If you store hazardous wastes longer than the regulated time or accept hazardous waste generated by another entity, you may be considered a treatment, storage, and disposal (TSD) facility subject to TSD permitting requirements.)
  • Properly dispose of hazardous wastes. Ensure that all hazardous wastes are delivered to a permitted hazardous waste facility, or a facility that beneficially uses or reuses, or legitimately recycles or reclaims the waste.
  • Report annually to DEQ on the types and quantities of hazardous waste generated and how or where the hazardous waste was stored, treated, or disposed.
  • Report biennially to EPA on the quantities and types of hazardous waste generated and how it was managed (treated, stored or disposed).

Hazardous Waste Shipping Instructions (Manifest Information)

Anytime a hazardous waste is moved off-site, a manifest is required to accompany the waste. The manifest is designed to track waste from the time it leaves the generator until it arrives at a permitted hazardous waste treatment, storage, or disposal facility. The manifest allows waste generators to verify that wastes have been properly delivered and that no waste has been lost or unaccounted for in the process.

Idaho does not require copies of manifests to be submitted to it regardless of whether the waste originates or is disposed of in the state. The only exception is when Idaho DEQ is the generator of the waste.

Idaho does not have any state-specific waste codes.

Treatment, Storage, and Disposal Facilities

Facilities where hazardous waste is treated, stored, or disposed are required to have a permit. Learn more.


DEQ State Office - Waste Management & Remediation Division

1410 N. Hilton
Boise, ID 83706
(208) 373-0502

Staff Contacts

Hazardous Waste Regulation & Policy Coordinator
John Brueck
(208) 373-0458
john.brueck@deq.idaho.gov

Hazardous Waste Analyst
Rene Anderson
(208) 373-0210
rene.anderson@deq.idaho.gov

Hazardous Waste Generator Forms

DEQ Resources

Summary of Idaho Hazardous Waste Generator Requirements

Conditionally Exempt Small Quantity Generator (May 2007)

12 Questions to Ask about Your 180-day Hazardous Waste Storage Site: Poster (January 2004)

11 Questions to Ask about Your Waste Drum: Poster (January 2004)

More Information

Hazardous Waste Generators

Resources for Generators

Hazardous Waste Manifest System
Access information and forms on EPA's website to track and report on hazardous waste generated.

Related Pages

Sump Waste

Spent Solvents

Used Oil

How to Obtain an EPA Identification Number

Pollution Prevention