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FAQs

Providing details about the self-certification program.

Does a New Hampshire Small Quantity Generator (SQG) need to notify NHDES and obtain an EPA Identification number?

Yes, every generator of hazardous waste needs to notify NHDES prior to conducting activities that would generate or result in the accumulation of hazardous wastes. Transporters of hazardous waste also need to notify and obtain an EPA ID number. Download a copy of the form.

 

What is the purpose of the SQG Self-Certification?

This certification form is for SQGs to use when certifying to NHDES that their company is in compliance with applicable hazardous waste rules. The self-certification program is required under RSA 147-A:5, IV, NH Hazardous Waste Law. The intent of the SQG Program is to increase the awareness, knowledge, and compliance rates of SQGs. The law requires SQGs to review their hazardous waste procedures, conduct an inspection of their facility, and certify compliance to NHDES. HW-27 Hazardous Waste Small Quantity Generator Self-Certification Program.

 

Who must submit the SQG Self-Certification?

Each generator of hazardous waste that creates one drop to less than 220 pounds (approximately 26 liquid gallons) of hazardous waste in any calendar month of its operation must submit this form to NHDES once every three years, together with the fee.

 

What is the SQG Self-Certification fee?

SQGs must submit a fee of $90 per year, payable every three years at the time of certification. If you are renewing your self-certification (SQG Form), the associated fee is $270. If this is an initial submittal, the fee may differ, as all generators are responsible for retroactive fees.

 

How do I know if I have a hazardous waste?

By testing the final waste and/or using your knowledge of the process that created it. A good rule of thumb is that if you are using your EPA ID # and a manifest to ship your waste, there is the strong likelihood that you are a hazardous waste generator.

Fact sheets:
HW-11 Identification of Hazardous Waste
HW-35 Documenting Hazardous Waste Determinations

 

I only generate one gallon of hazardous waste per month. Do I have to be part of the program?

Yes. If you generate or have hazardous waste on site, you will need to complete the form and pay the fee.

 

I just have a parts washer. Do I have to comply with the requirements?

If you are using a hazardous parts washer, the resultant waste will be hazardous and you must comply. If you are using a non-hazardous parts washer, it could become contaminated through use. The waste (not the original solvent) should be tested or you should have proof based on knowledge to document if the waste is hazardous or non-hazardous. Fact Sheet HW-31: "Is My 'Non-Hazardous' Parts Washer Solution Hazardous?"

 

Can I dispose of hazardous wastes through my community's household hazardous waste day?

Possibly, depending on the event. Env-Hw 511.01(f) allows SQGs to transport 55 gallons or less of hazardous waste to a household hazardous waste collection event, provided the waste is transported using a uniform hazardous waste manifest (with your EPA ID#, not the towns), is given directly to a NH registered transporter during the event and permission is obtained from the town prior to transportation to the event. Please see the NHDES fact sheet "SQG Self-Transportation to Household Hazardous Waste Collection Events."

 

Is training required for SQGs?

No, any training that is offered by the SQG Program is voluntary and is designed to assist you in filling out the forms and to help you better understand how to manage your wastes. It is also free. Trainings typically occur in the fall of each year. More information can be found on the SQG Training page. Annual training is required for all FQGs, however, SQGs can attend (for a fee) if they would like to get more in depth training. Please see the Hazardous Waste Coordinator Certification page for more information.

 

I no longer generate hazardous waste. What do I do?

If your company no longer generates hazardous waste, an Inactivation/Declassification Form must be submitted to NHDES with a final hazardous waste manifest proving that all hazardous waste has been removed from the property.

 

I only generate used oil that is recycled. Do I need to comply with the SQG Program?

No, if the used oil is recycled and is truly the only hazardous waste you produce, you would not need to notify as an SQG. Used oil that is not recycled or is managed under Env-Hw 500 as a NH listed hazardous waste would be subject to the SQG program and the fee. Please note that if you are generating any oil other than automotive oil, you must conduct an initial used oil determination to ensure that your oil is not regulated as a hazardous waste for reasons other than the NH01 listing. For more information on used oil, visit the Used Oil Management page.

 

What is a universal waste and are they exempt from the SQG Program?

“Universal Wastes” include waste antifreeze, mercury-containing devices, fluorescent lamps, batteries and cathode ray tubes (CRTs). Although SQGs are subject to the Universal Waste Rule, they do not need to count that waste toward their hazardous waste status or include it on the SQG Form, as long as it is being managed appropriately and is being recycled.

 

Does my municipal government need to comply? How about public school districts?

Yes, if they generate small quantities of hazardous waste, they need to complete the SQG Form. However, both are political subdivisions and are exempt from the fee. Please note that state agencies are not exempt from the fee.

 

Do SQGs have to ship their hazardous waste off within 90 days of beginning to accumulate the waste? 

An SQG may accumulate up to 220 pounds of non-acutely hazardous waste on site for an indefinite period of time provided that they comply with the requirements of Env-Hw 508.02. In addition, an SQG may accumulate up to 2,200 lbs. of non-acutely hazardous waste on site for an indefinite period of time provided that they comply with the requirements Env-Hw 508.03, the Small Quantity Generator Extended Accumulation Provision. If the 2,200-pound storage limit is reached, all of the hazardous waste must then be shipped off within 90 days.

 

At what point do I become a Full Quantity Generator (FQG)?

If, in any one month, you generate or create more than 220 pounds of hazardous waste and/or have more than 2.2 pounds of acutely hazardous waste accumulated, you would need to notify NHDES that you are an FQG by calling our Reporting Section at 603-271-2921 or emailing them at hazwastereporting@des.nh.gov. Please note that SQGs can accumulate more than 220 lbs. of non-acute hazardous waste per month under the Extended Accumulation provisions. Hazardous Waste Coordinator Certification Program.

 

Where can I get a copy of the New Hampshire Hazardous Waste Rules?

You can order a copy by telephone at (603) 271-2975 or download them through the Administrative Rules library.