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VSQGs fly without EPA ID, unless…
The very small quantity generator (VSQG) regulations in §262.14 do not require VSQGs to obtain an EPA ID number or ship hazardous waste on a manifest. However, what happens if the VSQG’s treatment, storage, and disposal facility (TSDF) requires VQSG loads to be shipped on a manifest? Or if the VSQG has an episodic event managed under Part 262, Subpart L, which requires episodic wastes to be shipped on a manfest? [§262.232(a)(5)]
In the past, TSDFs were required to send a paper copy of the manifest back to the customer. As of January 22, 2025, this was no longer true because a new EPA e-manifest rule went into effect requiring final copies of the manifest to be submitted to the e-manifest system. [89 FR 60692] And as of December 1, 2025, exception and discrepancy reports must be submitted through the e-manifest system, too.
From a practical standpoint, a VSQG shipping hazardous waste on a manifest may need an EPA ID number if they must access the e-manifest system to obtain the final manifest or submit reports—even though it’s not a regulatory requirement. Find more about VSQG requirements in our white paper and visit us online for more compliance morsels.
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