Daniels Training Services

Small Quantity Generators of Hazardous Waste “Basic Plan” for Emergency Preparedness and Response

Small Quantity Generators of Hazardous Waste “Basic Plan” for Emergency Preparedness and Response

If you are a Small Quantity Generator (SQG) of hazardous waste, you may be aware that the regulations of 40 CFR 262.34(d)(4) require you – along with large quantity generators and treatment storage and disposal facilities – to comply with the Emergency Preparedness and Prevention regulations of 40 CFR 265, Subpart C.  You may not be aware of the requirements of 40 CFR 262.34(d)(5) which apply solely to SQG’s.  These regulations are sometimes referred to as an SQG’s “Basic Plan”.  They include the following:

  1. At all times there must be at least one employee either on the premises or on call ( ie. available to respond to an emergency by reaching the facility within a short period of time) with the responsibility for coordinating all emergency response measures.  This employee is the emergency coordinator.
  2. 40 CFR 262.34(d)(5)(iii) requires an SQG to “ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies”.  This is typically interpreted to mean some kind of training.
  3. The following information must be posted next to any telephone that may be used in a hazardous waste fire, spill, or emergency:
  • The name and telephone number of the emergency coordinator;
  • Location of fire extinguishers and spill control material, and, if present, fire alarm; and
  • The telephone number of the fire department, unless the facility has a direct alarm.
40 CFR 262.34(d)(5)(iv) goes on to specify the applicable responses for an SQG’s emergency coordinator in the event of a fire, spill, or an event that could threaten human health outside the facility or a spill that has reached surface water:
  • Fire:  Call the fire department or attempt to extinguish it using a fire extinguisher.
  • Spill:  Contain the flow as much as possible and, as soon as practicable, clean up the waste and any contaminated materials or soil.
  •  Threaten human health outside the facility or spill to surface waters:  Immediately notify the National Response Center (800.424.8802) and report the following information:
    1. The name, address, and U.S. EPA Identification Number of the generator;
    2. Date, time, and type of incident (e.g., spill or fire);
    3. Quantity and type of hazardous waste involved in the incident;
    4. Extent of injuries, if any; and
    5. Estimated quantity and disposition of recovered materials, if any.

Being a Small Quantity Generator of hazardous waste does not relieve you entirely of the burden of regulatory compliance.  Make certain that you are in compliance with all the regulations applicable to SQG’s; attend my training or contact me with questions.