Preparing Your 2018 Biennial Reports – We’re Here if You Need Us

Federal regulations require all RCRA hazardous waste Large Quantity Generators (LQGs) to submit a report every 2 years summarizing the waste they generated and where it went. This "Biennial Report" is due by March 1 of every even-numbered year, and it covers hazardous waste generated the previous year (2017, in this instance).

• You are a RCRA LQG if, in any month, your site generates more than 1,000 kilograms of hazardous waste, more than 1 kg of acutely hazardous (P-list) waste or more than 100 kg of acute hazardous waste spill debris or residue
• Only RCRA hazardous waste counts towards this total, not non-RCRA waste (for California generators), universal waste or medical waste

The Biennial Report includes the EPA Site Identification (Site ID) form for your site plus one Waste Generation and Management ("GM") Form for each RCRA waste generated, with certain exclusions and exceptions. Forms and instructions are at https://www.epa.gov/sites/production/files/2018-07/documents/2015_smm_msw_factsheet_07242018_fnl_508_002.pdf. Different states have different procedures for submitting the reports. For example, in California, generators must submit Biennial Reports online and then mail the Certification page and "Declaration of Electronic Filing" with original signatures to DTSC. Reports for 2017 activities are due by March 1, 2018, so it’s time to start preparing and gathering your hazardous waste information! Please see this short video from Jim Kapin (Manager of EHS consulting for ACT) for additional information. If you have any questions, or would like assistance preparing your 2018 Biennial Report, please contact your ACT Account Manager or email [email protected].