Questions about Compliance? Contact Us Today! 1-800-351-9563

Generator Status

Step 2. Determine your generator status

Every business in Idaho is required to track the volume of wastes generated, determine whether or not each type of waste is hazardous, and ensure that all wastes are properly disposed of according to federal, state, and local requirements.

Remember, you must prove that you are not a Small or Large Quantity Generator.   You must have documentation clearly establishing the quantities disposed of during your operations.

Conditionally Exempt Small Quantity Generator (CESQG)

You are a CESQG if you generate:

  • 220 pounds or less of hazardous wastes per calendar month
  • 2.2 pounds or less of acutely hazardous wastes per calendar month

As a CESQG, you are required to:

  • Keep track of your waste by identifying all hazardous wastes generated and determining the total amount generated and stored on-site each month. Be prepared to document that you are within the limits for this classification. You are not required, but may wish, to obtain an EPA Identification Number to track quantities, types, and movement of hazardous wastes you generate.
  • Limit on-site storage of hazardous wastes you generate to no more than 2,200 lbs. at any time.
  • Properly dispose of hazardous wastes. Ensure that all hazardous wastes are delivered to an approved municipal solid waste landfill or permitted hazardous waste facility, or a facility that beneficially uses or reuses, or legitimately recycles or reclaims the waste.

Small Quantity Generator (SQG)

You are an SQG if you generate:

  • more than 220 but less than 2,200 pounds of hazardous wastes per calendar month
  • 2.2 pounds or less of acutely hazardous wastes per calendar month

As an SQG, you are required to:

  • Keep track of your waste by identifying all hazardous wastes generated and determining the total amount generated and stored on-site each month.
  • Obtain an EPA Identification Number to track quantities, types, and movement of hazardous wastes you generate.
  • Limit on-site storage of hazardous wastes you generate to no more than 13,200 lbs. for 180 days or less (or 270 days if treatment, storage, and disposal facility is more than 200 miles from generator facility). (If you store hazardous wastes longer than the regulated time or accept hazardous waste generated by another entity, you may be considered a treatment, storage, and disposal (TSD) facility subject to TSD permitting requirements.)
  • Properly dispose of hazardous wastes. Ensure that all hazardous wastes are delivered to a permitted hazardous waste facility, or a facility that beneficially uses or reuses, or legitimately recycles or reclaims the waste.
  • Report annually to DEQ on the types and quantities of hazardous waste generated and how or where the hazardous waste was stored, treated, or disposed. Link to state reporting form and instructions.

The majority of painting and mold remediation contractors will fall in the category of Conditionally Exempt Small Quantity Generator or Small Quantity Generator.  Only large scale commercial operations would likely exceed the quantity limits within these categories.

Large Quantity Generator (LQG)

You are an LQG if you generate:

  • 2,200 or more pounds of hazardous wastes per calendar month
  • more than 2.2 pounds acutely hazardous wastes per calendar month

As an LQG, you are required to:

  • Keep track of your waste by identifying all hazardous wastes generated and determining the total amount generated and stored on-site each month.
  • Obtain an EPA Identification Number to track quantities, types, and movement of hazardous wastes you generate.
  • Limit on-site storage of hazardous wastes you generate to no more than 2.2 lbs. of acutely hazardous wastes for 90 days or less. (If you store hazardous wastes longer than the regulated time or accept hazardous waste generated by another entity, you may be considered a treatment, storage, and disposal (TSD) facility subject to TSD permitting requirements.)
  • Properly dispose of hazardous wastes. Ensure that all hazardous wastes are delivered to a permitted hazardous waste facility, or a facility that beneficially uses or reuses, or legitimately recycles or reclaims the waste.
  • Report annually to DEQ on the types and quantities of hazardous waste generated and how or where the hazardous waste was stored, treated, or disposed.
  • Report biennially to EPA on the quantities and types of hazardous waste generated and how it was managed (treated, stored or disposed).

Hazardous Waste Shipping Instructions (Manifest Information)

Anytime a hazardous waste is moved off-site, a manifest is required to accompany the waste. The manifest is designed to track waste from the time it leaves the generator until it arrives at a permitted hazardous waste treatment, storage, or disposal facility. The manifest allows waste generators to verify that wastes have been properly delivered and that no waste has been lost or unaccounted for in the process.

Idaho does not require copies of manifests to be submitted to it regardless of whether the waste originates or is disposed of in the state. The only exception is when Idaho DEQ is the generator of the waste.

Idaho does not have any state-specific waste codes.

Treatment, Storage, and Disposal Facilities

Facilities where hazardous waste is treated, stored, or disposed are required to have a permit. Learn more.