Counting Hazardous Waste

What is Counting?

Counting is the informal word used to describe the process of totaling the quantity of a person’s hazardous wastes to determine compliance with a specific law. For example, a generator must count (i.e., must add up or total) the entire quantity of hazardous waste it produces (generates) in a month, pursuant to section 66262.34 of Title 22, to determine its generator status (SQG, or LQG) for that month.

Besides counting for purposes of section 66262.34, generators may have to count for other purposes, such as, for consolidated manifesting eligibility, to determine its generator fee category, for biennial reporting applicability, etc.

Counting Purpose Chart

Are All Hazardous Wastes Counted?

Not always. Generally speaking, for purposes of monthly generator status, all hazardous wastes, except for universal wastes, must be included in a count. However, for other purposes, only certain hazardous wastes are to be counted. For example, for RCRA Biennial reporting, only generators who produce greater than any of the following must complete the report:

• Greater than 1000 kg of RCRA hazardous waste in a month, or
• Greater than 1 kg of RCRA acutely hazardous waste in a month, or
• Greater than 100 Kg of spill (cleanup) residue contaminated with RCRA acutely hazardous waste.

As can be seen from this example, generators must pay particular attention to exactly what must be counted when counting. Materials which are not hazardous wastes, as that term is defined in section 66261.3, are not included in such counts.