How Do I Manage My Hazardous Waste?

Information presented in this publication is intended to provide a general understanding of the statutory and regulatory requirements governing hazardous waste. This information is not intended to replace, limit or expand upon the complete statutory and regulatory requirements found in the Illinois Environmental Protection Act and Title 35 of the Illinois Administrative Code of Regulations.

If you generate hazardous waste, this publication will help you understand how to properly manage it so that you protect your employees and the environment, and comply with the law. Ask yourself the following questions to determine your hazardous waste management requirements. 

What Type of Hazardous Waste Generator Am I?

The hazardous waste regulations that apply to you depend on the amount of hazardous waste you generate per month. There are three categories of hazardous waste generators:

  • Conditionally exempt small quantity generators (CESQG) generate less than a total of 100 kilograms (220 pounds) per month of hazardous waste.

  • Small-quantity generators (SQG) generate a total of 100 to 1,000 kilograms (220 to 2,200 pounds) per month of hazardous waste.

  • Large-quantity generators (LQG) generate over 1,000 kilograms (2,200 pounds) per month of hazardous waste.

To determine your hazardous waste generator category, add up the weight or volume of all your hazardous waste generated per month.

What is a Hazardous Waste Manifest?

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If your generator category changes from month to month, you may want to follow the larger category requirements to ensure you are always in compliance.

The manifest allows the waste to be tracked during shipment and at its final destination. All SQGs and LQGs must use the Illinois Uniform Hazardous Waste Manifest or an SQG can enter into a tolling agreement with a recycling facility for all hazardous waste that is shipped from their business. 

What Requirements Apply to CESQGs?

  • Identify all hazardous waste that you generate.

  • Hire a licensed special waste hauler to transport your hazardous waste to a facility permitted to receive hazardous waste. 

  • Do not accumulate more than 1,000 kilograms (2,200 pounds) of hazardous waste on your property at any time.

  • If you accumulate more than 220 pounds of special waste, you must use a hazardous waste manifest. 

  • Store all hazardous waste in containers such as drums.

What Requirements Apply to SQGs?

  • Accumulate hazardous waste in containers such as 55-gallon drums or tanks.

  • Do not store hazardous waste on your property more than 180 days. You may store the waste for up to 270 days if it will be transported greater than 200 miles from your business

  • Do not accumulate more than 6,000 kilograms (13,200 pounds) of hazardous waste on your property at any time.

  • Register with the Illinois Environmental Protection Agency (Illinois EPA) using a Notification of Hazardous Waste Activity form.

  • Make sure all your hazardous waste is packaged and labeled correctly before transport. Although you are responsible for packaging and labeling your waste, ask your transporter for assistance with this requirement.

  • Hire a licensed special waste hauler to transport your hazardous waste to a permitted hazardous waste facility using the Illinois Uniform Waste Manifest or the manifest of the state you are shipping the waste to or sign a tolling agreement with a recycling facility. 

  • Keep your hazardous waste manifests or a copy of your tolling agreement at your business for three years

  • If you do not receive a copy of the manifest signed by the disposal company within 60 days of shipment, send a copy to Illinois EPA of the manifest copy left by the transporter.

What Requirements Apply to LQGs?

If you are an LQG, there are many additional requirements that you must comply with in addition to the requirements described in this fact sheet. 

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Although a licensed transporter ships your waste,  you are responsible for ensuring that the transporter and the facility that accepts your waste manage your waste properly. 

Can I Collect Waste Near the Process?

Yes, an Satellite Accumulation Area (SAA) allows you to accumulate hazardous waste near where you generate it. You may accumulate up to 55 gallons in containers that must be labeled "Hazardous Waste." Once you accumulate 55 gallons in the SAA, you have three days to move the waste to a 90-day accumulation area. Write the date you move the waste on the container and ensure that the waste is removed from your business within 90 days from that date.

Should I Prepare for an Emergency?

All SQGs must establish safety guidelines and emergency response procedures and be equipped with the following:

  • An internal communication or alarm system that can provide immediate emergency instructions to all personnel;

  • A telephone or two-way radio to request emergency assistance from local police and fire departments;

  • Portable fire extinguishers, fire control devices, spill control materials, and decontamination supplies; and

  • Adequate water volume and pressure to supply water hoses, foam-producing equipment, or automatic sprinklers.

Are there any Requirements for the Containers I use to Accumulate Hazardous Waste?

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To protect the environment and reduce your regulatory requirements, minimize the amount of waste you generate. 

All SQGs must:

  • Label each container with the words "HAZARDOUS WASTE," and mark each container with the date you start accumulating the waste in a 90-day accumulation area.

  • Use a container made of or lined with a material that will not cause hazardous waste stored in it to react, ignite, or explode.

  • Keep all containers of hazardous waste closed except when adding or removing waste.

  • Do not open, handle, or store containers in a way that might cause them to leak, rupture, or fail.

  • Inspect areas where containers are stored at least weekly for leaks and deterioration.

  • Maintain the containers in good condition. If a container leaks, put the hazardous waste in another container.

  • Do not mix incompatible hazardous waste or materials unless precautions are taken to prevent potential hazards.