Hazardous Waste (SQG) Program FAQs

Answers to frequently asked questions about the Small Quality Generator program and waste management for facility owners.

  • 1. What are the main functions of the SQG Program?

    The primary function of the SQG Program is inspecting facilities to ensure that they properly manage and dispose of hazardous waste. These inspections are typically done periodically and are unannounced. The program also provides information and training to SQG generators on how to reduce or eliminate hazardous waste and investigates citizen complaints.

  • 2. What is an SQG (Small Quantity Generator)?


    A business, government entity or other facility that generates more than 100 kilograms (about half a 55 gallon drum) but less than 1000 KG (about five 55 gallon drums) of hazardous waste in any one month. Examples are:
    • Vehicle Repair Shops
    • Boat Builders
    • Electroplaters
    • Paint and Body Shops
    • Dry Cleaners
    • Pest Control Companies
    • Photo Processors
    • Medical Facilities
    • Furniture Refinishers
    • Laboratories
  • 3. What at my business is considered "Hazardous Waste"?

    Products containing hazardous materials that have been damaged during shipment, discontinued supplies, products having an expired shelf life, discarded paints, spent solvents, waste degreasers, cleaning compounds, or byproducts of chemical processes can be considered "hazardous waste". Your business also may have a waste that is listed in the Code of Federal Regulations (CFR) as being hazardous waste, or it may possess one of the following characteristics: Ignitability, Corrosivity, Reactivity, or Toxicity.

  • 4. How do I identify my wastes?

    All generators of waste materials are required by law to identify and evaluate their waste. The following steps are suggested for identification:

    • Check the Material Safety Data Sheet (MSDS) for product information
    • Check with your supplier/manufacturer.
    • Read the product label.
    • Compare product information with the listed wastes and hazardous waste characteristics in 40 CFR 261.

    If product information is not available, your only alternative is to have a commercial laboratory sample and test your waste.

  • 5. Now that I have established my business as an SQG, what must I do?

    • Use a multiple copy manifest,
    • Obtain an EPA/DEP identification number,
    • Accumulate no more than 6,000 kilograms (13,200 pounds)of hazardous waste for longer than 180 days,
    • Implement a Preparedness and Prevention Plan,
    • Use a DEP-approved transporter for off-site shipment of hazardous waste,
    • Dispose hazardous waste only at a permitted RCRA facility,
    • Maintain a copy of the manifest for a period of three years,
    • File an exception report if a copy of the manifest is not returned from the disposal facility within 60 days of the date the waste was shipped.

  • 6. The SQG requirements seem extensive. What other options can I consider?


    Your best strategy is to reduce or eliminate waste, thereby changing your generator category. Here are some simple suggestions:
    • Measure and control use of materials. This can be as simple as setting a limit on the number of rags to be used on each job or as complex as instituting a pharmacy system for materials distribution.
    • Inspect incoming materials. Defective goods are more easily returned upon delivery than at a later time.
    • Use a “first-in, first-out” inventory method to eliminate outdated materials.
    • Keep lids closed on anything that can evaporate.
    • Recover, recycle, and reuse waste on site.
    • Participate in a waste exchange (link www.wastexchange.org)

    A Conditionally Exempt Small Quantity Generator (CESQG) generates no more than 100 KG (about half a 55 gallon drum) of waste in any one month. As a CESQG, you are only required to ensure proper disposal of hazardous waste and keep documentation of the disposal.

  • 7. What is a Material Safety Data Sheet?

    Some hazardous wastes are chemicals that require Material Safety Data Sheets (MSDS); which must be obtained from the manufacturer at the time any hazardous chemical is purchased. The purpose of the Material Safety Data Sheet is to familiarize the user of chemicals to any hazards associated with that chemical. MSDS contain valuable information such as:


    • The identity (trade name) on the label
    • Physical and chemical characteristics
    • Physical hazards, including the potential for fire, explosion, and reactivity
    • Health hazards, including signs and symptoms of exposure
    • Primary routes of entry (inhalation, ingestion, absorption, and injection)
    • General precautions for safe handling and use, including hygienic practices and procedures for a cleanup of spills and leaks
    • Emergency and first aid procedures


  • 8. What is a hazardous waste manifest?

    A hazardous waste manifest must accompany most hazardous waste that is shipped off site. The Uniform Hazardous Waste Manifest is the shipping document that travels with hazardous waste from the point of generation, through transportation, to the final treatment, storage, and disposal facility (TSDF). Each party in the chain of shipping, including the generator, signs and keeps one of the manifest copies, creating a "cradle-to-grave" tracking of the hazardous waste.  EPA ID numbers are needed by all parties on the manifest.

  • 9. Can I throw used oil filters into my regular garbage?

    No. They should be completely drained of any free flowing oil (preferably “hot drained” and crushed). Place them into a weather tight container marked "Used Oil Filters". They can be hauled to an approved facility and disposed there, or you can contract with a specialty transporter to have them hauled to an appropriate facility.  Maintain a disposal receipt at your facility.

  • 10. I have two locations for my businesses. Can I keep all my records together in one location?

    No, each location must maintain separate records documenting disposal/recycling process. If you have a different billing location that needs the receipts make a copy for yourself. Keep all records on site for three years.

  • 11. I use green tip "environmentally friendly" fluorescent bulbs. Can they be put in the regular trash?

    All fluorescent bulbs/devices are considered hazardous waste because they contain the heavy metal mercury. Green tipped light bulbs may have a smaller amount, but they still contain mercury. Lamps or devices with any mercury must be recycled under the Universal Waste Rule or be counted as a hazardous waste by the generating facility.

  • 12. I put my used antifreeze directly in with my used oil. Is this correct?

    No. All waste should be stored separately. Never mix any potential hazardous waste with another waste. If the antifreeze happens to be hazardous it would contaminate the entire container of used oil leaving the responsible party with hazardous waste to dispose of, which is much more expensive. Keep all wastes separate with the correct labels.

  • 13. I use acetone (or any solvent) on disposable rags and throw them out when they are dry. Is this a proper disposal method?

    No. Even though the rags are dry they still contain hazardous waste.   Do not use disposable shop rags in certain processes at your facility. If you do use disposable rags and they are contaminated, they must be stored and disposed of as hazardous waste.  Another option is to contract with a uniform/shop towel service that will supply you with clean rags on a regular basis. These contractors are permitted by state and local agencies to process/wash the rags, which are considered a recyclable item. Used rags should be placed into a properly labeled, closed-lid container. Keep all receipts for a minimum of three years. Do not mix rags together with different wastes into the same storage container, as they may be reactive to one another and become a fire hazard.

  • 14. What containers need to have labels?

    All containers that hold waste must have the proper label (e.g. USED OIL, USED OIL FILTERS, USED ANTIFREEZE, HAZARDOUS WASTE). The label must include:

    ·         The words “Hazardous Waste-Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency”;
    ·         Generator’s Name and Address;
    ·         Manifest Document Number.
    ·         The container should also include a description of the waste and the date the waste was first put into the container (accumulation start date).

  • 15. If I take my used oil to an auto parts store for community collection, how can I prove it?

    Keep a logbook at your business that records the date, amount taken and what location the oil was taken to. Used oil is not a hazardous waste as long as it never hits the ground and is properly recycled though a documented process.

  • 16. How do I dispose of my "household hazardous wastes" such as unwanted pesticides, paints, etc.?

    The government does not regulate hazardous wastes generated in the home. Paint products, pool chemicals, household cleaners, and pesticides are typical examples. When disposed of in the municipal solid waste stream or otherwise improperly managed, these materials have the potential of contaminating the groundwater - our drinking water supply.  To reduce impacts to our groundwater, Manatee County operates a household hazardous waste collection center. For information on hours for drop off, call the Solid Waste Division at 792-8811.

  • 17. Where can I find a good source for additional information on Small Quantity Generator requirements?

    Download the document entitled “Florida’s Handbook for Small Quantity Generators of Hazardous Waste”   Any business owner may contact NRD to schedule a compliance assistance visit.