Hazardous Waste Generator Program

Overview April 27, 2016

The purpose of the hazardous waste program is to ensure that all hazardous wastes are properly handled, recycled, treated, stored and disposed of.

The State of California Department of Toxic Substances Control authorizes San Mateo County to inspect and regulate hazardous waste generators in San Mateo County based on the Hazardous Waste Control Law found in the California Health and Safety Code Division 20, Chapter 6.5 and regulations found in the California Code of Regulations, Title 22, Division 4.5. These regulations require businesses generating any amount of hazardous waste as defined by regulation to properly store, manage and dispose of hazardous waste. Our staff conducts annual inspections at businesses to assess compliance with state and federal law and regulations.

If your business generates any amount of hazardous waste, you must obtain a County permit. Complete the Registration Form and submit it to envhealth@smcgov.org.

What is a Hazardous Waste?

The generator of the waste shall determine if that waste is a hazardous waste by applying their knowledge of the characteristics of the waste or by testing it according to the approved methods to determine:

if the waste is excluded from regulation;
if the waste is listed as a hazardous waste;
if the waste exhibits ignitable, corrosive, reactive or toxic characteristics.

If the waste is determined to be hazardous the generator must comply with all applicable requirements.

Hazardous waste is divided into different types (e.g., universal waste, recyclable waste, etc.) or categories, including RCRA hazardous waste and non-RCRA hazardous waste. Properly categorizing a hazardous waste is necessary for land disposal restrictions, treatment standards, and fees. For additional information about waste determination, click here.

What are the Applicable Requirements?

Hazardous waste generators need to comply with applicable federal and state laws and regulations applicable to their generator category, the type of hazardous waste, and the process that generates the waste. In California, there are two generator categories:

Small Quantity Generators (SQG): Generate < 1,000 kg of hazardous waste per month, excluding universal wastes, and/or 1kg or less of acutely or extremely hazardous waste per month
Large Quantity Generators (LQG): Generate 1,000 kg or more of hazardous waste per month, excluding universal wastes, and/or more than 1 kg of acutely or extremely hazardous per month

California did not adopt the conditional exemption for smaller quantity generators in 40 CFR 261.5 including the counting requirements found in that section. Therefore, in California generators of 100 kg or less of hazardous waste per month are regulated as SQGs and not Conditionally Exempt Small Quantity Generators (CESQGs) as they would be under the federal hazardous waste management program. There are still some provisions that apply to CESQs. For example, they can dispose of their hazardous waste to a Very Small Quantity Collection Facility.

LQG facilities have additional and more stringent requirements than SQGs. It is the responsibility of the facility to determine the generator status and comply with applicable requirements.

For a list of requirements based on the generator category, click here.

Do I Need a Hazardous Waste ID Number?

Any facility who generates, transports, offers for transport, treats, stores, or disposes of hazardous waste (All are collectively called “handlers”.) generally must have an ID number, which is used to identify the hazardous waste handler, and to track the hazardous waste from the point of origin to its final disposal.

Permanent ID numbers are issued to people or businesses who routinely generate hazardous wastes. Temporary ID numbers are issued to people or businesses who do not typically generate hazardous waste; these ID numbers are valid only for 90 days. You must request a permanent ID number if you need to have another ID number after your temporary ID number expires.

Facilities must determine if they need a Federal or a State ID number. Federal EPA ID numbers are issued to handlers of federally regulated hazardous wastes (AKA RCRA hazardous waste). This includes generators of more than 100 kg of RCRA hazardous waste and/or more than one kg of acutely hazardous waste. EPA ID numbers are site-specific. All other handlers of hazardous waste are issued State ID numbers. State ID numbers are owner and site-specific.

Generators who produce, in each month, less than or equal to 100 kilograms of RCRA hazardous waste that is hazardous only due to silver, such as spent photo-processing solutions, do not need an ID Number. This exemption does not apply if the generator produces any other hazardous waste or is otherwise required to get an ID Number.

Apply for an ID Number
For State ID Number: Complete the form DTSC 1358 and submit it to the Department of Toxic Substances Control (DTSC).

For Federal EPA ID Number: Complete the form EPA 8700-12 and submit it to DTSC. Applications can be also submitted using the myRCRAid website. GO to the U.S. EPA’s RCRA info login page to create an account. Then complete the steps to apply for a Federal EPA ID.

Keeping your ID Number Active
Facilities need to submit the electronic Verification Questionnaire (eVQ) annually. Failure to submit the eVQ by the deadline will inactivate your number. If you don’t have an account yet, go to the eVQ website to register. Once you have an eVQ account, you will receive reminders to certify the ID number and avoid inactivation.

Reactivating your ID Number
All numbers that were not certified during the certification period have been inactivated by the State. If you are unsure of the status of the ID number for your facility, look it up on the Hazardous Waste Tracking System website.

ID numbers can be reactivated electronically or by completing the required forms. Click on this link for instructions on how to reactivate your State or federal ID number.

Emerging Wastes: Vapes (E-Cigarettes)

Key requirements that apply to businesses:

Schools and businesses that find vapes in their trash or confiscate them become a hazardous waste generator. All hazardous waste generators must register with Environmental Health Services for a permit. Generators also must register with DTSC for an EPA ID number to ship waste including using the VSQG Program (limit of 20 vapes per drop-off).
Businesses must determine their generator category. Consider monitoring how much nicotine liquid is being stored. Nicotine liquid is an acutely hazardous waste. Businesses that store over 2.2 pounds (1 kg) of nicotine waste at any time or generate over 2.2 pounds in a calendar month are considered large quantity generators and are subject to significant compliance requirements. See a comparison of LQG and SQG requirements here.
Train those that handle vapes about the hazards, how to protect themselves, store the waste properly, and other hazardous waste management requirements.
Be aware of accumulation time limits. Typical accumulation time limits are 90 days for large quantity generators and 180 days for small quantity generators.
VSQG businesses may self-transport to the VSQG Program.
Businesses shipping hazardous waste must use an active California registered hazardous waste transporter number. Here is a Hazardous Waste Haulers List for your reference.
Ensure hazardous waste is tracked on a manifest to an appropriate destination facility for proper management and treatment.
See a more comprehensive discussion of generator requirements on the DTSC guidance page.

How does a school or business determine the vape waste is hazardous waste?

It is the responsibility of the business or person generating waste to determine if the waste they need to discard is a hazardous waste. The chart below is provided as a reference. For more information on how to make that determination, a self-guided course can be found here.

Waste Type in Vapes	Typical Hazards	Is it Hazardous Waste/What kind?
Nicotine (e-liquid) in cartridge or pod	Acutely toxic if absorbed through skin or swallowed	Acutely hazardous waste
Cannabis (e-liquid) in cartridge or pod	May be toxic to aquatic life	DTSC FAQ: Excluded from the definition of hazardous waste by HSC 25141.5.1 (plant and cannabis waste when it solely exhibits the hazardous waste characteristic of toxicity)
Batteries: Lithium-ion or other types in a vape (removable)	Metals and electrolytes – toxic Potential to cause fires	Universal waste
Electronics: Ex. Vape with cartridge and battery removed – contains electronics	Metals – toxic	Universal waste
“Disposable” all-in-one e-cigarette (nicotine). Contains cartridge with liquid residue, battery, and electronics*	Electronic board – toxic*	Acutely hazardous waste
“Disposable” all-in-one cannabis vape. Contains cartridge with liquid residue, battery, and electronics	Lithium-ion battery – toxic, fires Electronic board – toxic*	Universal waste

*Do not disassemble. Some items not meant for disassembly or easy battery removal may result in fires, sparks, or other hazards when disassembly is attempted.

Note: Universal waste is hazardous waste managed under less rigorous regulations.

How does a school or business find a transporter?

Once a determination is made, a proper transporter can then be considered. StopWaste’s resource guide is linked here but the references have not been verified or approved by San Mateo County. They are provided as a starting point to assist businesses in finding appropriate transporters for their situation.

Additionally, here is a Hazardous Waste Haulers List.

How does a school or business train staff?

Facility staff will require different levels of training depending on their responsibility and whether the facility is an LQG or an SQG. More details here. The basics of training may include:

Awareness of the hazards, like those mentioned above, and how to protect yourself when handling the waste.

Ex. Wear gloves and place any components into an individual plastic bag before placing them into the appropriate hazardous waste container. Do not disassemble items unless they are meant for disassembly like an obvious or easily removable battery.

How to make a waste determination.
Using a proper container, labeling, and weekly inspection to manage the waste while it is being stored.
How to weigh or monitor waste quantity (weight) and the accumulation time limit.
How to clean up spills and respond to other emergencies like fires.
How and when to have waste picked up including any manifest procedures.

Hazardous Waste Disposal Options

Depending on the frequency and amount of hazardous waste generation, disposal options will vary:
Recyclable waste: Used oil, paint waste, and universal waste are considered recyclable hazardous wastes and there are alternative options for disposal for businesses that generate small quantities of these wastes. Businesses must check the quantity limits of each site before dropping off their waste. See the links below for disposal options:

Used motor oil collection centers
Paint Care collection centers
Universal Waste Resource List

Very Small Quantity Generator Program
Sites that generate less than 27 gallons (100 kg) of hazardous waste per month can dispose of their hazardous waste through the San Mateo County Very Small Quantity Generator (VSQG) Program. Hazardous waste generators need to provide a hazardous waste ID number to schedule an appointment to drop-off their waste.

To schedule an appointment at the VSQG location, go to smchealth.org/vsqg.

Hazardous Waste Haulers
If the facility generates over 100 kg of hazardous waste per month, the business cannot use the VSQG program and will need to schedule a hazardous waste pickup with a registered hazardous waste hauler. For a list of haulers click here.

Free Hazardous Waste Training

2025-2026 Training Courses:

San Mateo County Environmental Health Services is providing FREE hazardous waste management webinar training for businesses within San Mateo County that generate hazardous waste as part of operations and are classified as small quantity generators (SQGs). This training program covers the basics of hazardous waste identification, proper labeling, and accumulation, transportation, and disposal regulations for self-generated hazardous waste and universal waste as well as applicable recordkeeping requirements. Participants will receive a comprehensive course manual and student resource packet as electronic file downloads upon registration as well as a record of training and certificate of completion following the training.
- Sign up to reserve a spot
- Training Date Options:
  April 9, 2026 – 8:00 a.m. to 10:00 a.m.
  August 6, 2026 – 8:00 a.m. to 10:00 a.m.
  June 11, 2026 – 8:00 a.m. to 10:00 a.m.
- If the training you are interested in is full, sign up on the waitlist and we will contact you if space opens.
Watch a free 4-hour hazardous waste generator training that was recorded at the 24^th annual CUPA conference.
See the CUPA Conference information below for in-person training offered at the upcoming CUPA Conference.

CUPA Conference Free Training Class

Training Topic: Free Basic Hazardous Waste Training Session (4hr)
Date: TBD (March 23-26, 2026)
Registration: CUPA Conference Free Training Sessions
Meeting Location:
Town & Country, San Diego County
500 Hotel Circle North, San Diego, CA 92108-3005
Map/Directions
Course Description: The training will cover the basics of identifying what is a hazardous waste, proper labeling and
accumulation requirements, and record keeping requirements. An overview of RCRA waste vs. non-RCRA waste and generator
status (LQG, SQG or CESQG) will also be covered. Participants will receive a comprehensive course manual and a certificate of
completion.
To attend other sessions at the conference, you must register for a one day or full registration HERE. For more information, visit our Conference Homepage.

2026 28th Annual CUPA Training Conference

When: March 23rd – March 26th, 2026
Where:
Town & Country, San Diego County
500 Hotel Circle North, San Diego, CA 92108-3005

Check here for current Online Learning Management System offerings from CalCUPA Forum Board

CUPA Conference Free Training Class

Training Topic: Free Basic Hazardous Waste Training Session (4hr)
Date: TBD (March 23-26, 2026)
Registration: CUPA Conference Free Training Sessions
Meeting Location:
Town & Country, San Diego County
500 Hotel Circle North, San Diego, CA 92108-3005
Map/Directions
Course Description: The training will cover the basics of identifying what is a hazardous waste, proper labeling and
accumulation requirements, and record keeping requirements. An overview of RCRA waste vs. non-RCRA waste and generator
status (LQG, SQG or CESQG) will also be covered. Participants will receive a comprehensive course manual and a certificate of
completion.
To attend other sessions at the conference, you must register for a one day or full registration HERE. For more information, visit our Conference Homepage.

Hazardous Waste Facility Closure

A business that has generated hazardous waste during operations must close according to specific closure standards required under California hazardous waste regulations. Closure requirements protect the environment, business owners, communities, and property owners. At the time of closure, hazardous waste generators are required to demonstrate the proper removal and disposal of hazardous wastes and chemicals, the absence of visible contamination, and that there has been no release to the environment.

A business that generated hazardous waste in San Mateo County must follow the procedures established in the “Hazardous Waste Generator Closure Notification and Procedures” document. A business must submit a completed facility closure notification to CUPA 30 days before beginning closure activities. Large Quantity Generators (LQG) and Tiered Permitting (TP) facilities are required to submit a Closure Plan for approval. Small Quantity Generators (SQG) should submit a work plan in addition to the Closure Notification if decontamination or sampling is required to be conducted. A work plan is a simplified closure plan to document the sampling and decontamination procedures and any relevant facility history.

Additional Resources

San Mateo County and CUPA Forum Guidance Documents

Department of Toxic Substances Control Guidance Documents

Auto Repair/Auto Body

Hazardous Waste Training