Hazardous Waste Generator Program

Free Hazardous Waste Training

The 24th California Unified Program Annual Training Conference will be a VIRTUAL event each T, W & Th from March 22 thru March 31, 2022 (https://calcupa.org/conference/index.html).

General Description

If you or your facility is a generator of hazardous waste and/or universal waste you must follow federal and state hazardous waste laws. The intent of these laws is to ensure that hazardous waste is properly managed to protect public health and the environment. Alameda County Department of Environmental Health (ACDEH) Hazmat Division is charged with overseeing the Hazardous Waste Generator Program. ACDEH is certified by the California Environmental Protection Agency (CalEPA) as the local Certified Unified Program Agency (CUPA) responsible for implementing these laws and regulations.

If your business generates any amount of hazardous waste, you must obtain a permit through the CUPA. A permit may be obtained by submitting basic business information to the California Environmental Reporting System (CERS) with the hazardous waste generator business activity box checked and paying the fee once invoiced.


  • Inspect businesses for compliance with the Hazardous Waste Control Act and applicable regulations
  • Verify hazardous waste accumulation, labeling, container and tank management standards, and waste generator status
  • Respond to complaints of illegal disposal of hazardous waste
  • Issue permits and inspects businesses that treat hazardous waste.

The generator of the waste shall determine if that waste is a hazardous waste by applying their knowledge of the characteristics of the waste or by testing it according to the approved methods to determine:

  • if the waste is excluded from regulation;
  • if the waste is listed as a hazardous waste;
  • if the waste exhibits ignitable, corrosive, reactive or toxic characteristics.

If the waste is determined to be hazardous the generator must comply with all applicable requirements. 

Hazardous waste is divided into different categories; including RCRA hazardous waste and non-RCRA hazardous waste in addition to other waste types with special management allowances (e.g., universal waste, recyclable waste, etc.). Properly categorizing a hazardous waste is necessary to determine handling and treatment standards, land disposal restrictions, and fees. For additional information about waste determination, click here

Hazardous waste generators need to comply with applicable federal and state laws and regulations applicable to their generator category, the type of hazardous waste, and the process that generates the waste. In California, there are two generator categories:

  • Small Quantity Generators (SQG): Generate < 1,000 kg of hazardous waste per month, excluding universal wastes, and/or 1kg or less of acutely or extremely hazardous waste per month
  • Large Quantity Generators (LQG): Generate 1,000 kg or more of hazardous waste per month, excluding universal wastes, and/or more than 1 kg of acutely or extremely hazardous per month

California did not adopt the conditional exemption for smaller quantity generators in 40 CFR 261.5 including the counting requirements found in that section. Therefore, in California generators of 100 kg or less of hazardous waste per month are regulated as SQGs and not Conditionally Exempt Small Quantity Generators (CESQGs) as they would be under the federal hazardous waste management program. For CESQGs (generating less than 100 kg or 27 gallons of waste per month) There are still some provisions that apply. For example, in Alameda County CESQGs may dispose of their hazardous waste to one of the three Household Hazardous Waste Facilities (HHWF) if they meet the HHWF requirements. 

LQG facilities have additional and more stringent requirements than SQGs. It is the responsibility of the facility to determine the generator status and comply with applicable requirements.

For a list of requirements based on the generator category, click here

Any facility who generates, transports, offers for transport, treats, stores, or disposes of hazardous waste (All are collectively called “handlers”.) generally must have an ID number, which is used to identify the hazardous waste handler, and to track the hazardous waste from the point of origin to its final disposal.
Permanent ID numbers are issued to people or businesses who routinely generate hazardous wastes. Temporary ID numbers are issued to people or businesses who do not typically generate hazardous waste; these ID numbers are valid only for 90 days. You must request a permanent ID number if you need to have another ID number after your temporary ID number expires.
Facilities must determine if they need a Federal or a State ID number. Federal EPA ID numbers are issued to handlers of federally regulated hazardous wastes (also known as RCRA hazardous waste). This includes generators of more than 100 kg of RCRA hazardous waste and/or more than one kg of acutely hazardous waste. EPA ID numbers are site-specific. All other handlers of hazardous waste are issued State ID numbers. State ID numbers are owner and site-specific.
Generators who produce, in each month, less than or equal to 100 kilograms of RCRA hazardous waste that is hazardous only due to silver, such as spent photo-processing solutions, do not need an ID Number.  This exemption does not apply if the generator produces any other hazardous waste or is otherwise required to get an ID Number.
Apply for an ID Number
For State ID Number: Complete the form DTSC 1358 and submit it to the Department of Toxic Substances Control (DTSC).
For Federal EPA ID Number: Complete the form EPA 8700-12 and submit it to DTSC. Applications can be also submitted using the myRCRAid website. Go to the U.S. EPA’s RCRA info log in page to create an account. Then complete the steps to apply for a Federal EPA ID.
Keeping your ID Number Active
Facilities need to submit the electronic Verification Questionnaire (eVQ) annually. Failure to submit the eVQ by the deadline will inactivate your number. Go to the eVQ website to register and submit your eVQ.
Reactivating your ID Number
For State EPA ID Numbers (number starts with CAL, CAD, CAI, CAF, CAS, CLU, CAX, or CA99):
For Federal EPA ID Numbers (number starts with CAR, CA, CAD, or CAT):
  • If you did not complete your eVQ, go to the eVQ website and complete the forms. If you need to update your information, you must submit the EPA Form 8700-12 to DTSC.

Depending on the frequency and amount of hazardous waste generation, disposal options will vary:

If the facility generates over 100 kg. of hazardous waste per month, the business need to schedule a hazardous waste pickup with a registered hazardous waste hauler.  

Recyclable waste an Universal Waste: Used oil, paint waste, and universal waste are considered recyclable hazardous wastes and there are alternative options for disposal for businesses that generate small quantities of these wastes. Businesses must check the quantity limits of each site before dropping off their waste. 

Universal Waste

Universal Wastes are hazardous wastes that are generated by a wide variety of people and businesses that contain mercury, lead, cadmium, copper and other substances hazardous to human and environmental health. In general, UW may not be discarded into solid waste landfills.  Examples of UW include:

  1. Televisions
  2. Computers
  3. Computer monitors
  4. Batteries
  5. Fluorescent lamps.

See the links below for more information:

Used motor oil collection centers click here 

Paint Care collection centers and Large volume pickup 200 gallons or more click here

Universal wastes may be dropped of at the HHFW (click here for more information)

Fluorescent light bulbs may be taken back to the seller. Check with your provider.


Very Small Quantity Generator Program

Sites that generate less than 27 gallons (100 kg.) of hazardous waste per month can dispose of their hazardous waste through the Alameda County Household Hazardous Waste Facility. Hazardous waste generators need to accumulate waste in containers that are five gallons or less, submit an application, provide a hazardous waste ID number, and schedule an appointment to drop-off their waste.

For information on HHWF for business requirement and services click here

The Tiered Permitting Program regulates the onsite treatment of hazardous waste.
Treatment means any method, technique or process that changes the physical, chemical or biological character or composition of a hazardous waste, or removes or reduces its harmful properties or characteristics.
The State of California established a five-tiered program for authorizing the treatment and storage of hazardous waste at many businesses required to have State authorization, but not federal authorization (i.e., authorization under the federal Resource Conservation and Recovery Act or RCRA). The Department of Toxic Substance Control (DTSC) regulates Full and Standardized Permitted facilities. Alameda County CUPA regulates facilities in the following tiers:
1. Conditionally Exempt (CE) This tier allows onsite treatment of non-RCRA and RCRA-exempt hazardous waste (Health & Safety Code §25201.5(a) and (c), §25201.14, and §25144.6(c). This tier is for smaller quantities or less risky waste and treatment methods.:
2. Conditional Authorization (CA): This tier allows onsite treatment of non-RCRA and RCRA-exempt hazardous waste (Health & Safety Code §25200.3). This tier is limited to single-hazard wastes and treatment in the unit cannot exceed 5,000 gallons or 45,000 pounds in a calendar month.
3. Permit by Rule (PBR): This tier allows onsite treatment of non-RCRA and
RCRA exempt hazardous waste (California Code Regulations., Title 22, §67450.11). This tier is for more hazardous and higher volume wastestreams and processes than the other two lower tiers. If you are subject to tiered permitting you must submit the information in your CERS submittal. For more information regarding tiered permitting click here.

When a facility is closing or ceasing to generate waste they must notify ACDEH 30 days before the final closure. Large quantity Generators and Tiered Permitting Facilities are required to submit a closure plan for approval. See closure requirements here.