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State-Mandated Annual Reporting of the Biennial Hazardous Waste Report

State-Mandated Annual Reporting of the Biennial Hazardous Waste Report

Federal regulations of the Environmental Protection Agency (USEPA) at 40 CFR 262.41 require a generator who is a large quantity generator (LQG) of hazardous waste for at least one month in an odd-numbered year to submit the Biennial Report (aka: Biennial Hazardous Waste Report).  The generator must  complete the report using EPA Form 8700-13 A/B and submit it to the EPA Regional Administrator by March 1 of the following even-numbered year.

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A state with an authorized hazardous waste program may choose to make its regulations more strict than those of the USEPA.  One may that some states do this is to require an annual report from hazardous waste generators in their state.  Below is a table identifying the states by EPA Region that request an annual report instead of biennial from hazardous waste generators within their jurisdiction.

EPA RegionStates that require annual reporting
1Maine, New Hampshire
2New Jersey, New York
3Delaware, District of Columbia
4Georgia, Kentucky, Mississippi, South Carolina, Tennessee
5Illinois, Indiana, Michigan, Minnesota, Wisconsin
6Arkansas, Louisiana, Oklahoma, Texas
7Kansas, Missouri
8Montana
9Arizona, California, Guam
10`Idaho, Oregon, Washington

Other instances where state regulations for hazardous waste reporting are more strict than those of the USEPA:

  • Require reporting for small quantity generators (SQGs) of hazardous waste as well as LQGs.
  • Require reporting more frequently than annual, e.g. quarterly.
  • Collect a fee from hazardous waste generators.

Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste

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