Question (07.01.20):

Hi Daniel,

I’m subscribed to your newsletter and was wondering if you can help me with a question.

I manage the EHS program for two of <Company’s>> manufacturing facilities, and one of them is a very small quantity generator of hazardous waste (VSQG). Is this VSQG facility subject to the annual HazMat registration? I have heard different answers. We are part of a bigger parent corporation which is a large quantity generator of hazardous waste (LQG) but I’m not sure if this makes a difference since these are separate facilities. We always have our waste picked up for transport to a TSDF by an outside vendor.

Thank you in advance for your help.

My reply the same day:

I apologize for my delay in responding. Your email was caught by my spam filter. Please see below.

• A facility’s hazardous waste generator status is not a factor in determination of the USDOT/PHMSA registration requirements for shippers and carriers.
• However, hazardous waste is to be considered when determining the applicability of the six (6) criteria for registration.
• As defined by USDOT/PHMSA, the waste generated by a VSQG is not subject to USDOT/PHMSA a hazardous waste (I know, it sounds crazy, but that’s the way it is). However, the waste generated by a VSQG could be a hazardous material for other reasons, e.g., a spent solvent generated by a VSQG is not a hazardous waste but it may be a Class 3 Flammable Liquid and therefore a hazardous material subject to registration. Read: FAQ: How does USDOT/PHMSA classify a hazardous waste?
• As part of a bigger corporation it is most likely that the operations of all facilities within <<Company>> are covered by one corporate registration. If that is the case you need only obtain a copy of the following:
  • Registration statement filed with USDOT/PHMSA.
  • Certificate of Registration
  • form and ensure it includes the state(s) you operate in.
• The waste pickup and transport by an outside vendor is not a factor. You are still the shipper of the hazardous material (i.e., the person who offers).
• Please read: Registration with PHMSA as Shipper or Carrier of HazMat

I hope this helps. Please contact me with any other questions.

Another satisfied customer:

Thanks for the clarification!