I was talking to a student about the wonders of RCRA and he asked a question that I'm not sure of the answer to. Perhaps people on the list have some experience with it.

We were talking about the RCRA system of classifying waste generators into various classes based on the amount generated - large quantity generators, small quantity generators, etc. (I would note that New Hampshire does not follow the federal model in this regard, but I don't think that nuance affects this question.) The student asked whether there was a presumption that a particular waste generator was a large quantity generator until they proved otherwise or if a generator could presume to be a small quantity generator until proven otherwise by the regulator.

Complicating this question is the fact that the regulatory concept of waste generation rates is separate from the shipping of hazardous waste from a location in this regard. So you can't just look at your manifests to determine what size generator you are. The practical version of this question is how do people track intermittent waste generators such as labs to identify what size RCRA generator a location is?

Thanks for any experiences you have on this deep dive topic.

- Ralph

Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
603 358-2859

ralph.stuart**At_Symbol_Here**keene.edu

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