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.
Guide Hazardous Waste Generation & Generators
Important News & Updates
- On June 15, 2018, Massachusetts will move to the U.S. Environmental Protection Agency (EPA) online tool myRCRAid to help you obtain a hazardous waste generator identification number (EPA ID).
- This will allow you to use the new nationwide e-Manifest system, which EPA is introducing on June 30, 2018, to track hazardous waste shipments electronically.
- Using myRCRAid and e-Manifest will mean less paperwork, faster processing times, and more certainty for you.
- 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 the e-Manifest system.
- You may do this at no cost through myRCRAid after creating a RCRAInfo account. EPA will activate these systems for Massachusetts users on June 15, 2018.
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.
|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.
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 submit a notification form. See: 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 an ID Number
|PLEASE NOTE: Changes are coming on June 15, 2018, to the process of obtaining an ID number in Massachusetts. See Important News & Updates to learn more.|
Until June 15, 2018, use the current process if you are planning to generate, accumulate, or ship any hazardous waste and/or waste oil:
- Submit a Massachusetts Notification of Hazardous Waste Activity Form to the appropriate MassDEP Regional Office,
- Obtain a Generator ID Number from the agency, and
- Comply with all requirements that apply to your generator status.
Download the notification form from Additional Resources below. You may fill out and save the Microsoft Word version on your computer. The PDF form has to be printed out and completed by hand.
Hazardous Waste Manifest Requirements
|PLEASE NOTE: EPA will be moving the National Manifest Form to a new online platform on June 30, 2018. 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 the six-part National Manifest Form required by the U.S. Environmental Protection Agency (EPA).
The form needs to be completed and the various copies distributed according to the instructions. The appropriate waste codes, including those for wastes that are regulated by Massachusetts only (e.g. MA01 for waste oil), also need to be used.
A generator of hazardous waste and/or waste oil:
- Does not have to submit a copy of the manifest to MassDEP if the shipment goes directly to a Massachusetts hazardous waste facility.
- Does have to submit a fully executed photocopy of Copy 3 of the manifest to MassDEP within 30 days of receiving it if the shipment goes directly to an out-of-state hazardous waste facility. Copy 3 should be mailed to:
MassDEP Bureau of Air & Waste
One Winter Street, 7th Floor
Boston, MA 02108
See Additional Resources below for more information about the National Manifest System and EPA-approved manifest form printers.
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.
|Small Quantity Generators (SQGs)||Large Quantity Generators (LQGs)|
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.
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.