(“same”  means the state policy is the same as the federal policy)



Generator Exemption


The Waste itself

Where waste from CESQG can go?
Source- FR Vol. 64, No. 109, p.30434, June 8, 1999

Can the waste be declared non- hazardous, based on HW Characteristic (TCLP) see


Other stringency or exemptions?

Federal EPA

Generators producing less than 100 kg (220 pounds) of hazardous waste (HW) or 1 kg acute HW in each month, including all HW generated.  CESQGs are exempt from federal rules, but not exempt from liability (40 CFR 261.5)

Waste may go to any Municipal Solid Waste Landfill (MSWLF)

Wastes that test less than 0.2mg/l soluble mercury are not considered hazardous under federal rules.

Crushing not allowed as UW.  Can only be done by generator (40 CFR 262.34); crushed waste not UW- must be managed as RCRA HW.  No one may crush third-party lamps without treatment authorization [1] . 
No mobile treatment units.