Episodic Generation of Hazardous Waste

Mar 31, 2022 | EPA, Hazardous Waste, WI DNR

With the federal Generator Improvements Rule – the Environmental Protection Agency (EPA) established a conditional allowance for the episodic generation of hazardous waste. As a result, very small quantity generators (VSQG) and small quantity generators (SQG) can maintain their normal status while adequately disposing of more significant amounts of hazardous waste caused by a planned or unplanned event. In addition, encouraging the removal of any dangerous additional waste helps minimize the possibility of a fire, explosion, or any unexpected release of hazardous waste that could threaten human health or the environment.

What is an Episodic Event?

An episodic event is an activity, either planned or unplanned, that does not typically occur during a generator’s day-to-day operations. However, it often results in hazardous waste disposal, which exceeds the generator’s standard calendar month quantity limit.

Things to Keep in Mind Regarding the Episodic Generation of Hazardous Waste

  • This conditional allowance applies to Very Small Quantity Generators (VSQG) or Small Quantity Generators (SQG) only.
  • One planned or unplanned episodic event is allowed per calendar year. In addition, a facility may petition the EPA or state agency (the DNR in Wisconsin) for a second event. However, the second event must be unplanned if the initial event was a planned event, conversely, planned if the initial event was unplanned.
  • The generator must have an EPA id number or procure an EPA id number.
  • The generator must notify the EPA or the state agency (DNR in Wisconsin) no later than 30 days before a planned episodic event or within 72 hours for an unplanned episodic event.
  • An episodic event can last no longer than 60 days.
  • Common examples of an episodic event are a lab clean out with the removal of an excessive amount of expired chemicals, a facility move; an unexpected spill; or a natural disaster that requires a cleanup of hazardous material.

Lab Pack Hazardous Waste

Lab Clean Outs are Common Planned Episodic Events


How MERI Can Help

MERI’s hazardous environmental team can help you manage the waste from your episodic event.  First, we can help you determine if the additionally generated waste is hazardous (this determination needs to be done before submitting authorization of the event to the EPA or DNR). Our certified Environmental Manager provides lab packing services to help you characterize, segregate and package hazardous materials. Additionally, we can provide appropriately labeled DOT-approved containers. MERI provides manifests outlining the inventory before a licensed hazardous waste driver comes to collect and transport it to a licensed hazardous waste treatment facility for disposal. We will supply documents noting the date the disposal took place for your records

Where to Get More Information

Environmental Protection Agency (EPA) Final Rule: Hazardous Waste Generator Improvements: https://www.epa.gov/hwgenerators/final-rule-hazardous-waste-generator-improvements

Also, if in Wisconsin, take a look at the DNR’s guidance on the requirements for Episodic Generation of Hazardous Waste





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