Reporting Requirements for RCRA Small Quantity Generators – First Deadline September 1, 2025

Small Quantity Generators (SQG) of hazardous waste under the Resource Conservation and Recovery Act (RCRA) historically do not have as many Federal reporting requirements as Large Quantity Generators (LQG). However, as part of the Generator Improvements Rule (GIR) published in 2016, there was an additional report required for SQGs – the United States Environmental Protection Agency (U.S. EPA) Form 8700-12 (Site Identification form, Site ID Form) which certifies their RCRA hazardous waste generator status. LQGs are required to submit this certification every two years as part of their Biennial Reporting requirements. Title 40 of the Code of Federal Regulations (CFR) Part 262.18(d)(1) details the requirements for SQGs to certify their generator status using the Site ID form by September 1, 2021, then recertify every four years thereafter (Quadrennial Report).

Note: If your state has not adopted or been authorized to implement the GIR, this would not apply to your facility.

This means that if your SQG facility submitted their certification in 2021, the next time you would need to resubmit is in 2025. There is one caveat: if the facility has submitted a Site ID form (8700-12) in full any time within the period before the deadline, the renotification requirement has been met. If you are not sure if your facility has completed the form, in full, since 2021, it is recommended to resubmit the full recertification to meet this regulatory requirement. As additional clarification, U.S. EPA provided a notice that explained the deadline schedule as quadrennially starting September 1, 2021; the submission during the period before the deadline does not change when the recertification is due.

As an example, if your facility, in a state that has adopted the GIR, completed a full Site ID form by September 1, 2021, and again on June 30, 2024, the deadline for that period is still September 1, 2025. The requirement for that period (2021-2025) would be satisfied but the Quadrennial Reporting period would not be different for your facility (i.e., your next deadline would remain as submission by September 1, 2029, not June 30, 2028). The next deadline would still be to satisfy the reporting period of 2025-2029.

How do I submit this report?

Many states have annual reports that some or all generators of hazardous wastes are required to submit. U.S. EPA may not recognize these annual reports as satisfactory to meet the requirements for the Quadrennial Report, especially if the state does not use the RCRAInfo reporting module. To satisfy the requirement, your facility would need to either: be located in a state that annually uses RCRAInfo’s full Site ID form submission to satisfy the annual reporting requirements, or submit, independently of the state submission, through RCRAInfo.

What is RCRAInfo?

As an SQG, you may not have signed up for a RCRAInfo account, or even known it was an option! If you do not have an account, setting one up is simple. Visit U.S. EPA’s website for a walkthrough video: https://rcrainfo.epa.gov/rcrainfo-help/videos/CreateRIAAccount/Create%20RIA%20Account.html

Or U.S. EPA’s landing page for RCRAInfo registration: https://www.epa.gov/e-manifest/e-manifest-user-registration#how_register

As of January 22, 2025, all LQGs and SQGs are required to hold a RCRAInfo account to maintain an e-Manifest profile (Site Manager or e-Manifest Certifier permission) for their facility. RCRAInfo acts as an electronic manifest repository, discrepancy, and exception report communication method, as well as the preferred avenue for submitting your Quadrennial Report. If you already have a Central Data Exchange (CDX) account for another Federal report, the login credentials are the same and you can add access to the RCRAInfo module through CDX.

If you aren’t sure if anyone has access to your facility in RCRAInfo, reaching out to the state will start that process:  https://rcrainfo.epa.gov/rcrainfoprod/action/public/public-site/state-contacts

You can also search for your facility and request access using your U.S. EPA ID number in the Facility Search after confirming or completing your RCRAInfo account access.

If you have any questions about Biennial or Quadrennial Reporting, Hazardous Waste Generator Compliance, or using RCRAInfo, reach out to Michelle Carter at mcarter@all4inc.com.