Household
Hazardous
Waste
SOP 3.8: Very Small Quantity and
One-Time Generator Waste Acceptance
Contents
1.
Introduction ....................................................................................1
2.
Regulatory and Contractual Requirements .......................................1
3.
Training Requirements .....................................................................1
4.
Health and safety precautions ..........................................................2
5.
Prior to Implementing a VSQG Program ............................................2
6.
Obtaining a VSQG Collection Site License ..........................................3
7.
Process for Accepting Business Hazardous Waste..............................3
8.
US DOT Materials of Trade (MOT) Exemption ...................................5
Attachment A ............................................................................................6
1. Introduction
This Program shall be licensed by the state prior to acceptance of business hazardous waste (HW).
Minnesota HW rules allow for the establishment of licensed Very Small Quantity Generator (VSQG)
collection sites. The VSQG HW collection is optional for Household Hazardous Waste (HHW)
Programs and ensures a cost-effective and environmentally responsible choice for business HW
disposal.
2. Regulatory and contractual requirements
VSQG and One Time Generator (OTG) waste acceptance is governed by the requirements of the HHW
program/state agency contract (Exhibit A, part H), Minn. Rules ch. 7045, part 0320, subp. 9, C and D;
Department of Transportation (DOT) Title 49 Code of Federal Regulations (CFR), parts 261.5, 171.101,
172.101, subp. c(9); 172.203, subp. C; 172, subp. D; 172.204, 173, 173.6, and 173.8.
For US DOT information, call 888-472-3389 or 612-405-6120, or see: www.dotcfr.com. To apply for
a VSQG collection site license, call the Minnesota Pollution Control Agency (MPCA) at 800-657-3864.
3. Training requirements
Prior to accepting business waste, licensed VSQG collection site (Program) staff shall be fully trained
to accept and manage HW, including associated hazards and precautions. See:
http://www.pca.state.mn.us/index.php/view-document.html?gid=12875 and
SOP 1.4, HHW Training Requirements.
3.1
This Program shall assign designated staff to assist businesses in HW management. This
facility staff person is the Program Manager.
3.2
Thorough knowledge and training is needed in proper HW identification and hazardous
categorization (e.g., lab packing, shipping papers, land disposal restriction notifications,
labeling or markings, and packaging). The VSQG Program staff is recommended to attend
Train the Trainer training, offered by US DOT.
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3.3
This Program shall provide training for staff members who meet the US DOT definition of a
hazmat employee if job duties include offering hazardous materials (HM) for shipment (e.g.,
packaging, marking, labeling, creating or offering shipping papers, loading HW on vehicles).
3.4
US DOT training shall be systematic and ensure staff is knowledgeable regarding:

ability to recognize and identify HW

function-specific tasks appropriate to job duties

review of emergency response plans

safety, self protection, and accident prevention measures

review of HHW Facility US DOT Security plans
4. Health and safety precautions
Precautions for the overall health and safety of staff shall be addressed (e.g., personal protective
equipment use requirements, preventing environmental impacts). See SOP 2.1, AWAIR and
SOP 2.13, Medical Monitoring Program. Staff shall be alert for suspicious circumstances involving
business-generated wastes. Experienced staff performing normal HHW operations shall use good
judgment and follow established Program protocol when questionable deliveries of suspected
business HW are attempted. See SOP 4.1, Receiving Wastes From Participants.
5. Prior to implementing a VSQG Program
5.1
Program staff shall fully comprehend the extra workload required to assist business HW
generators. See: http://www.pca.state.mn.us/index.php/view-document.html?gid=10616.
5.2
Program staff working specifically with business HW issues shall be fully knowledgeable with
VSQG acceptance requirements. The Program staff is recommended to tour established
HHW licensed VSQG collection sites to review the:
5.3
5.4

initial information packages sent out to business generators serviced

fees or charges for HW disposal

advertising policy used

computer program or method used for tracking and invoicing incoming business HW. To
view a VSQG application, see: www.pca.state.mn.us/oea/publications/hhw-application715.pdf

process used to ensure proper shipping paper completion.
Prior to accepting business waste, the Program is recommended to establish an advertising
policy for the VSQG hazardous waste disposal service; see:
http://www.pca.state.mn.us/index.php/view-document.html?gid=10618. Businesses
interested in HW disposal often learn about the VSQG Program from advertising policy,
which may include:

to use word of mouth as the sole advertising method

to place monthly ads in local newspapers or on the radio

to print up refrigerator magnets or brochures to handout at the facility, annual fairs,
collection events, or other public events
Facility staff shall be able to answer VSQG-related questions and provide guidance to the
businesses by becoming familiar with US DOT transport and shipping requirements
including:
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5.5

the shipping paper completion process

hazard communication

HW classification

HW packaging labeling and marking

HW segregation during transport
Licensed collection programs may pick up hazardous materials from a VSQG business
generator as part of the service they provide. The US DOT regulations allow government
entities to transport hazardous materials from a generator using only its own employees
and vehicles in volumes up to 1,000 pounds (Materials of Trade (MOT) exemption only
allows up to 440 pounds) and if no charge or fee is associated for the transport service.
Commercial VSQG collection programs would be fully regulated under the Hazardous
Material Regulations and required to comply with all Hazardous Waste Transporter
requirements, including manifesting.
6. Obtaining a VSQG collection site license
6.1
Each business is categorized based on the amount of HW generated annually:

Large Quantity Generator (LQG): greater than 2,200 pounds per month.

Small Quantity Generator (SQG): greater than 220 pounds per month, but less than
2,200.

Very Small Quantity Generator (VSQG): generates up to 220 pounds (or about 22
gallons of liquid) per month.

One-Time Generator (OTG): a one-time only disposal of up to 2,200 pounds of HW per
generator. OTG hazardous waste is typically abandoned materials or from a one-time
clean-out event. Waste cannot be generated from the business’s normal operating
processes.

Minimum Quantity Generator (MQG0 – Ten gallons or 100 pounds per year per
generator.
6.2
This Program shall obtain state approval prior to accepting business HW quantities greater
than a Minimal Quantity Generator (MQG). For more information, see SOP 3.7, Minimal
Quantity Business Generated Waste. To apply for a license to operate a VSQG collection site,
contact the MPCA or see Section 2 of this SOP. Submit completed application to the state
for review and approval.
6.3
Upon license approval, the Program shall be allowed to also accept HW from businesses
qualifying as a VSQG, OTG, or SQG. LQG and SQG-sized generators cannot be accepted at a
licensed VSQG consolidation site. The LQG and SQG wastes shall not be manifested,
commingled, or managed using this Program’s HW identification number.
6.4
On a report provided by the State, the HHW Program shall submit data on an annual basis.
7. Process for accepting business hazardous waste
7.1 This Program shall implement the following policy while accepting business HW:

The businesses shall contact this Program to inquire about specific requirements prior to
bringing in hazardous waste.

This Program shall provide the VSQG with introduction materials (e.g., program flyer,
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costs for disposal, application, and an inventory sheet to list HW disposal items. See
Section 2 of this SOP).

The business shall complete and return all required forms to Program staff for review.
From the information submitted, Program staff shall determine if the material meets the
definition of hazardous waste and can be accepted.

The table below is a brief summary of acceptable/unacceptable materials:
Acceptable Materials
Unacceptable Materials
Latex paints oil base paints
Ammunition radioactives
Batteries lab pack materials
Explosives biohazards
Fuels
HW generated from SQGs
Aerosols antifreeze
HW generated from LQGs
Pesticides
Fluorescent light bulbs
ballasts, waste oil, filters, or
sorbents
HW generated from MQGs
HW generated from OTGs
HW generated from VSQGs
7.2 Program staff shall verify and confirm the business’s HW generation status using the HW
Generator identification number provided by the business. Greater Minnesota HHW programs
can access the state’s database website; see Section 2 of this SOP. A VSQG Licensed Collection
Program is not subject to the protection provided by the indemnification provision if the
regulatory limitations for HW quantities are exceeded. If necessary, staff may assist the
business to obtain an HW Generator identification number from the state. To verify the
current status of a business HW generator, see: www.pca.state.mn.us/waste/epaID/. To
obtain an HW identification number, see: http://www.pca.state.mn.us/index.php/viewdocument.html?gid=10623
7.3 Facility staff shall provide the business with a billing estimation prior to HW drop off. Staff
shall schedule a time with the business to bring in the HW to the Facility.
7.4 Qualifying businesses may transport their HW to this Facility for proper disposal, following US
DOT requirements to ensure compliance; see Attachment A of this SOP. To determine if DOT
MOT exemptions apply for reduced transport requirements, see Section 8 of this SOP. For a
printable “Transportation Guidelines for VSQG Collection Programs” booklet, see:
http://www.pca.state.mn.us/index.php/view-document.html?gid=9023.
7.5 Upon arrival at the Facility, Program staff shall weigh and document the HW types and
weights. Computer programs (e.g., QuickBooks, Access) provide an easy method for
documenting totals, drafting reports, and tracking waste.
7.6 Program staff shall provide the business with an invoice as proof of proper disposal. The
business and VSQG Program shall keep documentation for a minimum of three years
(preferably indefinitely). Information from disposal invoices or shipping papers may be used
by this Program to generate the state VSQG report (required annually). The report constitutes
renewal of the annual VSQG license and summarizes information from businesses serviced by
this Program, including:


HW quantities accepted
HW types accepted
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
number of businesses utilizing the service
7.7 Business HW may be commingled with HHW and is subject to state indemnification, provided
the HW is shipped off site by the state-contracted HW disposal company and authorized
transporter; see SOP 4.4, Lab-packing. Materials deemed usable may be placed in the Facility
product exchange or reuse area.
8. US DOT Materials of Trade exemption
8.1 Business HW may qualify to be transported to a licensed VSQG collection site using the US
DOT MOT exemption. It is the discretion of this Program policy whether or not to utilize this
exemption. If the Program chooses the more stringent policy of not utilizing the US DOT MOT
exemption, see Attachment A of this SOP. The MOT exemption allows for reduced shipping
and transport requirements, including:
 no shipping paper
 no placarding
 no US DOT labels
 less HW transportation training
 drivers are not required to carry the Transportation Guidelines for VSQG Collection
Programs booklet
8.2 Drivers shall be instructed on the MOT exemption and be informed of the presence of the HW
on the transport vehicle. The driver shall be able to recognize and demonstrate knowledge of
the HW carried.
8.3 To satisfy the US DOT MOT exemption, business HW shall not be manifested or classified as
Poison Inhalation Hazard (PIH), acute or self reactive. The HW shall be:






packaged in the size limited by packing group or type of container used. No one container
shall have a gross mass or capacity greater than 66 pounds or eight gallons (for packing
groups II and III)
transported in amounts less than 440 pounds (aggregate gross weight)
contained in sturdy, leak-proof, closed and sift-proof packages
secured against movement and protected from damage
marked with correct US DOT shipping name or common name
restricted to the following:
Hazard Class
Hazard Division
3 - flammable liquids
2.1 - flammable gases
2.2 - non-flammable gases
4.1 - flammable solids
–4.3 Water reactive or Dangerous
when wet
7- radioactives
5.1 - oxidizers
8 - corrosives
5.2 - organic peroxides
9 - miscellaneous HM
6.1 - poison liquids or solids
ORM-D - consumer commodities
6.2 - infectious substances
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Attachment A
DOT Requirements for Transporting Business HW
(49 CFR 173.24)
1. Waste classification
1.1 US DOT requires the HW transporter to describe and classify their materials based on DOT
hazard definitions prior to shipping or transporting. For more information, see CFR 49, parts
100-185 Hazmat, or www.dotcfr.com. This information is needed for proper shipping paper
completion.
1.2
Evaluate the waste stream to determine if it is hazardous waste. Subsidiary hazard classes
shall be entered in “( )” in shipping descriptions (e.g., acetic acid, glacial 8(3), UN2790, II). This
information is needed for proper shipping paper completion.
1.3
Be aware of acute or P-listed HW. When a quantity greater than one kilogram (about a quartsized container) of acute hazardous waste is generated per month, the business no longer
qualifies as a VSQG and cannot use this Program. P-listed wastes include commercial chemical
products or manufacturing intermediates such as pesticides or cyanide compounds and the
listed chemical is the sole active ingredient.
1.4
Program staff shall assist the business to evaluate and assign a shipping classification to each
container using:





US DOT proper shipping names
EPA waste codes; see:
http://www.dehs.umn.edu/hazwaste_chemwaste_umn_cwmgbk.htm
Hazard Precedence Table (49 CFR 173.2a)
Knowledge of the hazardous waste (e.g., MSDS, label information)
US DOT hazard class or division definitions, which include:
Hazard Class
Hazard Division
1 – explosives*
1.1 – mass explosive hazard*
2 – compressed gas
1.2 – projection hazard*
3 – flammable and combustible liquids
1.3 – mass fire hazard*
4 – flammable solids
1.4 – minor explosive hazard*
5 – organic peroxides
1.5 – very insensitive explosives*
6 – poison liquids and solids
1.6 – extremely insensitive explosives*
7 – radioactives*
2.1 – flammable gases
8 – corrosives
2.2 – non-flammable gases
9 – miscellaneous HM
2.3 – poison or toxic gas
ORM-D – consumer commodities
4.1 – flammable solids
4.2 – spontaneously combustible materials
4.3 – dangerous when wet
5.1 – oxidizers
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Hazard Class
Hazard Division
5.2 – organic peroxides
6.1 – poison liquids or solids
6.2 – infectious substances*
* Waste class not accepted at this Program
2. Packaging
2.1
Businesses that do not qualify to use the MOT exemption are required to transport HW in
proper packaging. “Package” means the shipping package and its contents. “Non-bulk”
packaging is a capacity less than or equal to 119 gallons for a liquid, a net mass of 882 pounds
for a solid.
2.2
Packages shall be packed upright, secured, and cushioned to control movement during
transport. Fill all void space with compatible absorbent materials to prevent breakage or
leakage. Cushioning or absorbents compatible with contents of inner package are
recommended. Faulty or damaged packaging shall not be used. Each container shall:
 contain only one class of HW per container
 be of sturdy construction
 be packaged in the size limited by the DOT packing group or container type
 have adequate closure
 display the proper DOT shipping name
 display the proper hazard class label
3. Shipping papers
3.1 A VSQG or OTG business may use a shipping paper in lieu of a manifest to transport waste to a
licensed VSQG collection site. Any material not listed on the shipping paper shall not be
transported. To view a sample shipping paper, see: http://www.pca.state.mn.us/index.php
/view-document.html?gid=10620.
3.2
US DOT requires shipping papers to include the following information:
 type and count of HW identified—class or division shall include technical name and waste
code
 generator HW Identification Number issued by the MPCA
 hazardous material description (the words “Hazardous Waste” and the HW code shall not
be included in the shipping description)
 emergency response information
 carrier name (handwritten signatures required) and date of acceptance
 the receiving facility name and address (handwritten signatures required)
 the business generator name and address (handwritten signatures required)
3.3
Drivers transporting HW shall have shipping papers in their possession at all times and know
the location of the emergency phone number listed on the shipping paper. The emergency
response number listed must connect to a live person with knowledge of the materials being
transported.
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3.4
Both this Program and the generator shall keep a copy of the shipping paper documenting
proper HW disposal. Shipping papers shall be immediately available for inspection on request
of authorized officials. Retain all shipping documents on file for a minimum of three years
(preferably indefinitely).
4. Labels and markings
Example of packaging information for magnesium powder
1H2/X25/S/0506/USA/XXX
These markings indicate an open head plastic drum, holding
Packing Group X materials, that shall hold a solid with gross
weight < or = 25 kilograms and was manufactured in the
United States by XXX Company in June, 2005.
The inner package shall be a plastic receptacle per 49 CFR
173.203. The magnesium powder was placed into a 1-pint size
plastic inner container and overpacked into a 5-gallon plastic
bucket and displays the UN symbol. (49 CFR 178 subp. L)
Hazard labels indicate the hazard class or
division of the material. Attach all required
labels to HHW packages, including:
 a completely filled out yellow EPA HW
label listing the proper shipping name
 a hazard class label shall be visible and
placed within six inches of other labels
 markings shall not conflict with the
prescribed color, design, or shape of attached labels
5. Transporting business HW
5.1 Responsibility for safe and legal transportation of HW ultimately lies with the shipper.
Businesses may transport HW to their own licensed site (which is part of that same collection
program) or to a VSQG Program approved by the state. Self transport by a business is limited
to 1,000 pounds of non-acute HW per vehicle. Following receipt and approval of the Program
application, the businesses shall be provided with clear instruction on transport requirements,
including:
 a properly completed shipping paper
 appropriate hazard DOT labels and/or markings
 the “Transportation Guidelines for VQSG Collection Program” booklet. For a printable
copy of the booklet, see: http://www.pca.state.mn.us/index.php/viewdocument.html?gid=9023.
 Drivers transporting business HW are required to read, sign, and have in their possession,
the “Transportation Guidelines for VQSG Collection Program” booklet. The driver
transporting business HW shall be aware of vehicle contents.
5.2
Staff shall remind the driver to deliver the HW directly and without delay.
5.3
All classes and divisions of HW and all packages shall be secured and braced to prevent
leaking, spilling, or falling during transport.
5.4
Incompatible wastes shall not be loaded, stored, or transported unless separated in a manner
that ensures no commingling of the materials shall occur. Class 8 materials shall not be loaded
on the transport vehicle above or next to Class 4 or Class 5 materials. Additional US DOT
requirements may apply, including restrictions for:






limited quantities
hazardous substances (reportable quantities or RQs)
Not Otherwise Specified (NOS) constituents
toxic constituents
poison by inhalation hazards
acute HW shall be shipped by a licensed transporter
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5.5
Licensed collection programs may pick up hazardous material from a VSQG business generator
as part of the service they provide. DOT regulations allow government entities to transport
hazardous material from a generator using only its own employees and vehicles in volumes up
to 1,000 pounds (MOT exemption only allows up to 440 pounds) and if no charge or fee is
associated for the transport service. Commercial VSQG collection programs would be fully
regulated under the Hazardous Material Regulations and required to comply with all HW
Transporter requirements, including manifesting.
6. Placarding transport vehicles
6.1
VSQG or OTG businesses transporting their own HW to a licensed VSQG Program do not
require placards except if aggregate gross weight is greater than 1,001 pounds or if the
material is listed in Table 2 of 49 CFR 172.504.
6.2
Although recommended, government vehicles are exempt from the US DOT placarding
requirements. If placards are used, they must be attached on each side and end of transport
vehicle or trailer, and shall reflect all classes of hazardous materials on board. Drivers shall:
 obtain a hazardous materials DOT endorsement on their driver’s license
 obtain drug and alcohol testing
 undergo a criminal background check
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