Guide Hazardous Waste Generation & Generators

Learn about Massachusetts hazardous waste generation, accumulation, labeling and manifest requirements, how to obtain a hazardous waste generator ID number, and annual compliance fees that apply to companies generating 220 pounds or more of hazardous waste per month.

Table of Contents

Important News & Updates

Massachusetts has moved to a pair of U.S. Environmental Protection Agency (EPA) online tools that make compliance with hazardous waste management regulations easier:

  • myRCRAid for obtaining generator identification numbers (EPA IDs), and
  • e-Manifest for documenting and tracking shipments electronically.

Using myRCRAid and e-Manifest means less paperwork, faster processing times, and more certainty for you.

Please Note: If you currently use a state-specific generator identification number beginning with “MV” to ship hazardous waste, you will need to obtain a new, properly formatted EPA ID before using e-Manifest. You may do this at no cost through myRCRAid after creating a RCRAInfo account.

Additional Resources for Important News & Updates

Generator Status & Storage Limits

Your hazardous waste generator status determines how much waste you may accumulate at your site at one time, and how quickly you need to ship it off-site for recycling or disposal.

Hazardous Waste Generator Classifications & Limits
Very Small (VSQG) Small (SQG) Large (LQG)
Generates less than 220 pounds (about 27 gallons) of hazardous waste or waste oil per month and no acutely hazardous waste. Generates between 220 and 2,200 pounds per month (roughly 27 to 270 gallons), and/or up to 1 kilogram (2.2 pounds) of acutely hazardous waste per month. Generates more than 2,200 pounds (about 270 gallons) and/or more than 1 kilogram (2.2 pounds) of acutely hazardous waste per month.
May accumulate up to 2,200 pounds (about 270 gallons) for an indefinite period of time. May accumulate up to 13,200 pounds (1,500 to 1,620 gallons) for no more than 180 days. May accumulate any quantity on-site, but must ship it within 90 days.

Note: The same numerical thresholds apply to both hazardous waste and waste oil. You may register separately and maintain a different generator status for each, depending on the quantities you generate.

See Additional Resources below to learn more about VSQG and SQG facility obligations, including accumulation limits and labeling requirements, and to obtain a current searchable/sortable list of hazardous waste generators in Massachusetts.

Additional Resources for Generator Status & Storage Limits

Why Following the Rules is Important

If you operate a business that generates hazardous waste or waste oil, here are some important things to know.

Before generating, accumulating, or shipping any hazardous waste, you need to obtain an ID number. If you fail to do this, you could be subject to enforcement and liable for fines of up to:

  • $1,000 per day for generating and accumulating hazardous waste or waste oil without a valid ID (a "temporary" ID is not acceptable). 
  • An additional $1,000 per day if you do not provide a valid ID on hazardous waste shipment manifests or don't submit manifests at all. 
  • $25,000 per day if you are found to be effectively operating a treatment, storage or disposal facility without a license.

Your hazardous waste transporter has the authority to refuse your shipments if you do not have your own valid ID, and might report you to MassDEP. Your insurance company may ask you to prove that you have a valid ID before issuing or renewing your property and/or casualty policy.

Obtain or Modify an ID Number

You need a valid ID number before performing any hazardous waste activity.
PLEASE NOTE: The process for obtaining or modifying a Hazardous Waste Identification Number (EPA ID) in Massachusetts has changed.

Before June 15, 2018, you had to mail a paper form to the Department of Environmental Protection (MassDEP) to obtain an EPA ID. MassDEP performed electronic data entry from paper submissions, then transferred the records it created to the RCRAInfo national database. This was a time-consuming process.

Now that Massachusetts has moved to the U.S. Environmental Protection Agency (EPA) online application myRCRAid - which allows you to apply for and obtain an ID electronically - the process works like this:

  1. Register as a RCRAInfo user (follow the link in Key Actions below).
  2. MassDEP approves your electronic signature. 
  3. Login at RCRAInfo, access myRCRAid, and apply for a an EPA ID by submitting a Site Identification Form electronically to MassDEP.
  4. The agency reviews your application, either approving it or asking you to make corrections and submit it again.
  5. Once approved, MassDEP issues your EPA ID through RCRAInfo and you are authorized to proceed with regulated hazardous waste activities.

It takes only minutes to create a RCRAInfo account and apply for an EPA ID via myRCRAid.

MassDEP will generally issue your EPA ID within seven (7) business days if the information you submit is complete and accurate. Please contact us if it takes longer. The agency has received an unusually high volume of requests for new IDs to meet EPA e-Manifest requirements, so appreciates your patience.

See the FAQ in Additional Resources below to learn more.

Key Actions for Obtain or Modify an ID Number

Additional Resources for Obtain or Modify an ID Number

Hazardous Waste Manifest Requirements

PLEASE NOTE: EPA has moved the National Manifest Form to a new online system. Learn more about e-Manifest. See the EPA Fact Sheet for Hazardous Waste Generators.

Under state and federal law, a facility that generates hazardous waste bears "cradle-to-grave" responsibility for the waste's creation, handling, transport, treatment and ultimate fate.

All Massachusetts waste generators and treatment facilities that initiate shipments of hazardous waste and/or waste oil must use manifests. Forms need to be completed with appropriate waste codes, including those for wastes regulated by Massachusetts only (e.g. MA01 for waste oil).

You may use the U.S. Environmental Protection Agency (EPA) e-Manifest system to complete, submit, and track manifests electronically. Here is all you need to do:

  1. Register as a RCRAInfo user (follow the link in Key Actions below).
  2. Wait for MassDEP to approve your electronic signature. 
  3. Login at RCRAInfo and access e-Manifest.
  4. Work with your transporter to complete and submit your manifest form(s) electronically.
  5. Track your hazardous waste shipment(s) online via RCRAInfo.

It takes only minutes to create a RCRAInfo account and between one (1) and seven (7) business days to begin using e-Manifest. See the FAQ in Additional Resources below to learn more.

Important Notes:

  • Although you may still use paper manifests, EPA and MassDEP strongly encourage you to use the e-Manifest system because it is an easier and less costly way to comply with the regulations.
  • You may still use existing MV plus phone number hazardous waste IDs (e.g. MV6170001111) on paper manifests, but will be unable to register as an e-Manifest user or track your shipments online until they are available on the public viewer after 90 days. MassDEP no longer accepts applications for new MV plus phone number IDs.

Key Actions for Hazardous Waste Manifest Requirements

Additional Resources for Hazardous Waste Manifest Requirements

Fees for Small & Large Quantity Generators

All facilities notifying MassDEP that they are small quantity (SQG) or large quantity (LQG) generators of RCRA-listed hazardous wastes receive annual compliance fee invoices from the agency, based on their generator status as of July 1.

MassDEP Annual Compliance Fees
Small Quantity Generators (SQGs) Large Quantity Generators (LQGs)
$645 $3,880

A facility wanting to cancel or change its hazardous waste generator status needs to formally notify MassDEP before July 1. Otherwise, it will be liable for the full annual compliance fee applicable to its status as of that date - even if it has stopped all hazardous waste activity at its location.

Additional Resources for Fees for Small & Large Quantity Generators

Large Quantity Generator Biennial Reporting

Each Large Quantity Generator (LQG) and Licensed Hazardous Waste Facility in Massachusetts is required to submit an 8700-13 (a)/(b) Hazardous Waste Report (also known as a Biennial Report) to the U.S. Environmental Protection Agency (EPA) every two years.

Starting in 2018, Biennial Reports will need to be filed electronically via the RCRAInfo Industry Application. The following information will need to be submitted:

  • RCRA Subtitle C Site Identification Form,
  • Waste Generation and Management (GM) Form,
  • Waste Received From Off-Site (WR) Form, and
  • Off-Site Identification (OI) Form.

See Additional Resources below to learn more about the new Biennial Reporting process.

Key Actions for Large Quantity Generator Biennial Reporting

Additional Resources for Large Quantity Generator Biennial Reporting

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