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DEQ's Hazardous Waste Reporting System
Frequently Asked Questions
Note: These are available to provide general guidance to Oregon facilities preparing annual Hazardous Waste Reporting forms. This information is not designed to provide strict legal interpretations of the terms and requirements contained in the forms, and is not legally binding. Refer to Title 40 of Code of Federal Regulations; to Oregon Revised Statute 466.005; to Oregon Administrative Rule 340-100; and to OAR 340-101 for precise legal wording.Expand All Content | Collapse All Content
Do I need to report?
Most facilities generating and/or managing hazardous waste in Oregon need to report to the Oregon Department of Environmental Quality, which is authorized by the federal government to administer hazardous waste programs in Oregon. DEQ sends information to small- and large-quantity generators about annual reporting in late December each year. The following categories have reporting requirements:
What if I need an extension to the reporting deadline?
Small- and Large-Quantity Generators must submit annual reports to DEQ by March 1 of each year to report the previous year’s hazardous waste activities. Facilities can request a one-month extension by:
How do I report if I sold my business?
The old and new business owner must decide if one owner will report for the full calendar year or if each owner will report for the portion of the year they were in business. If only one owner is reporting, then follow the appropriate directions below and check the box on the Site Identification form for “Filing for entire year” (in Section 1 “Reason for Submittal").
The following guidelines are provided to assist either owner. For assistance call DEQ’s Annual Report Hotline in Portland at 503-229-6938, or toll-free in Oregon at 1-800-452-4011, extension 6938.
Old Business Owner - Fill out the SI Form checking the box “To Withdraw Site Identification Number” and “Change in business ownership (representing the old owner).” Also, provide the following information:
New Business Owner - Reporting forms must be filed using paper forms because a signature is required from the new owner or his/her representative. Start with a SI Form that is pre-populated with the old owner’s information. There’s space to give the new ownership information. Call the Annual Report Hotline in Portland at 503-229-6938 or toll-free in Oregon at 1-800-452-4011, x6938 for assistance.
What is a hazardous waste?
Waste is defined as “hazardous” in Oregon for one of two reasons:
Wastes defined as hazardous based on one of the four characteristics listed above are known as “characteristic” hazardous wastes; wastes that appear on official lists are known as “listed” hazardous wastes.
Standards for determining the hazardous characteristics of ignitable, corrosive, reactive or toxic wastes can be found in 40 CFR 261.20-261.24. This 40 CFR section also describes tests generators should conduct on their wastes to determine if they’re hazardous.
In addition, any waste that is imported to Oregon from another state and is a state-only hazardous waste in the state of origin must be managed as it would be required to be managed in the state of origin. A regulatory definition of state-only hazardous waste can be found in OAR 340-101-0033.
Note: There are a number of state-only wastes that are not hazardous wastes and need not be reported on the annual reporting forms (e.g., X002 - PCBs). These are listed in What is not a hazardous waste?
What is an acute hazardous waste?
Acute hazardous waste is any hazardous waste with a waste code beginning with the letter "P,” or any state-only hazardous waste with a waste code beginning with the letters "P" or "ORP," or any of the following "F" codes: F020, F021, F022, F023, F026 and F027. These wastes are subject to stringent quantity standards for accumulation and generation. An example would be P076 for nitric oxide.
The following are not hazardous wastes and don’t need to be reported as a hazardous waste:
The following wastes have been assigned codes but currently are not regulated as hazardous waste and should not be reported on the reporting forms: X002 Polychlorinated biphenyls X004 Industrial waste (non-hazardous) X006 Lab pack (non-hazardous) X008 Household hazardous waste (including typical household garbage)
Finally, the following wastes are excluded from the definition of solid and/or hazardous waste as listed in 40 CFR 261.4 and 261.3(c)(2)(ii) and amended in OAR 340-101-0004. The following list is intended to be a general overview and is not all-inclusive. With the exception of Point Source Discharge Wastewater (See How do I report wastewater treatment units or elementary neutralization units?), these exclusions should not be reported on the Generation and Management Form.
Note: Some of these exclusions must meet very specific conditions. Refer to 40 CFR 261.4 and 261.3(c)(2)(ii) and OAR 340-101-0004 to make sure a specific waste qualifies.
When do I report hazardous wastes on the annual report?
Do report waste if:
Hazardous waste generators are regulated differently, depending on how much waste they generate or accumulate in each calendar month. There are three types of hazardous waste generators, each with different regulatory requirements.
Large-Quantity Generator – You’re a large-quantity generator, if in any one calendar month, you:
Small-Quantity Generator – You’re a small-quantity generator, if in any one calendar month, you:
Conditionally Exempt Small Quantity Generator – You’re a conditionally exempt small quantity generator, if in every calendar month, you:
Your actual generator status may change from month to month. However, for purposes of reporting, your classification is based on the greatest status by which you were regulated in any one month of the calendar year. Thus, if you were an LQG for only one calendar month of the year, you must report as an LQG on your forms. You’ll l report all of the waste generated for the entire year.
How do I identify individual waste streams?
Use your best judgment in identifying individual waste streams at your facility. Use the following guidelines:
Example: A liquid hazardous waste stream includes spent paint thinner and paint. The waste was generated by using the thinner to clean out paint guns. W209 is the form code for “Organic paint, ink, lacquer or varnish.” W211 is the form code for "paint thinner or petroleum distillates." Code W211 should be used since the thinner is the material that is spent and being discarded. The paint is merely contained within the spent thinner.
Example: An electroplating shop generates wastewater treatment sludge on a monthly basis. While F006 is the code for “Wastewater treatment sludges from electroplating operations,” the waste is also characteristic for corrosivity (D002) and chromium (D007). All three waste codes should be listed on the report form.
How do I report wastes with multiple management methods?
Many hazardous waste streams receive several types of management prior to final disposal. In most cases, only the final activity should be reported on the Waste Generation and Management form. The only exception is wastewater accumulated on-site prior to being managed in a wastewater treatment unit (See How do I report waste managed in wastewater treatment units or elementary neutralization units?).
If the residual from an on-site management activity is a hazardous waste, it should be reported as a separate waste stream on a separate Waste Generation and Management form.
Example: Spent solvent is recycled on-site in a distillation unit, leaving a still bottom. The still bottom is then sent off-site for incineration. On one Waste Generation and Management form, report the solvent as being managed on-site with a management code of H020, "Solvent Recovery.” On another such form, report the still bottoms as being managed off-site using the management code H040, "Incineration."
Spent material (e.g., used solvent) that is immediately transferred from a process unit to an on-site recycling unit is not required to be counted or included in the monthly waste accumulation generator category determination, if no storage or accumulation of the spent material has occurred prior to the recycling. See DEQ’s Hazardous Waste Policy 2001-PO-006 for more information on counting recycled hazardous waste.
Solvent waste such as paint thinners is often recycled on-site in distillation units, also known as stills. Waste that is managed in these units must be counted if accumulated or stored prior to recycling for purposes of determining your generator status, and reported on the Waste Generation and Management forms.
For solvent accumulated or stored prior to recycling, use the following guidelines for counting and reporting of this waste stream:
Spent materials are counted only once during the month the material becomes spent; no matter how many times the solvent was reused during that month. All still bottoms removed and makeup solvents added for use are also counted during the calendar month. The monthly waste total for the waste processed through the recycling unit will be the total pounds of the following three waste streams:
Total monthly waste = first batch (or maximum capacity of the recycling unit) + still bottoms + makeup solvent
Example: An on-site still recycles 10 gallons of paint thinner at a time. The facility operator runs a batch through the still four times in a month. Throughout the month, two gallons of solvent are lost in the distillation process, and fresh solvent must be added. Each run through the still generates one gallon of still bottoms. Once a month, four gallons of still bottoms are removed.
From this example, two waste streams must be counted and reported as follows:
Wastewater treated in units that release to a publicly owned treatment works sewer or to surface water under a National Pollutant Discharge Elimination System permit may be exempt from some hazardous waste requirements. If wastewater is transferred immediately (i.e., through an engineered conveyance device) from the system which generated it into a wastewater treatment unit, the waste is not counted toward generator status. However, these wastes must be reported on the Waste Generation and Management form using the management code H136: “Direct discharge to sewer/POTW.”
Wastewater that is hazardous only because it exhibits the corrosivity characteristic and is transferred immediately (i.e., through an engineered conveyance device) into an elementary neutralization unit is not counted toward generator status. However, these wastes must be reported on the Waste Generation and Management form using management code H121 "Neutralization only.”
Wastewater stored or accumulated at the facility without immediate introduction through an engineered conveyance device prior to entering a defined wastewater treatment unit or elementary neutralization unit, must be counted for purposes of determining generator status and reported on the Waste Generation and Management form using the code H135 “Discharge to sewer/POTW or NPDES with prior storage.”
Example: An electroplating operation generates chromium-contaminated wastewater that is collected in 55-gallon drums and stored for no more than 90 days. The waste is then transferred into an on-site wastewater treatment unit where the chromium is precipitated out and the water is discharged to a POTW. Since the wastewater does not immediately enter the wastewater treatment unit, it must be counted toward generator status and reported on the Waste Generation and Management form. Use the management code as H135: "Discharge to sewer with prior accumulation or storage."
Note: Any hazardous sludges or residuals removed from a wastewater treatment unit must be counted toward determining generator status and must be reported on the annual report. Use an additional Waste Generation and Management form. Hazardous wastewater transported by a vessel to an offsite wastewater treatment unit should be reported using the management code that best describes the treatment process.
Example: Chromium-contaminated wastewater is pumped into a tanker truck and transported to a treatment, storage and disposal facility where the chromium is precipitated out. The waste is then released into a river under an NPDES permit. Report the total amount of waste shipped as being managed offsite with the code H077: "Chemical precipitation."
How do I report periodic or one-time waste generation?
Periodic or one-time waste generation means generation of waste from non-routine events, such as cleanup of spills or discarding of out-of-date products or chemicals. This includes remediation-derived waste generation, such as generation as a result of a Superfund or state remedial action or RCRA closure of a hazardous waste management unit. Generation of these wastes, including investigation-derived waste, must be reported on the Waste Generation and Management forms.
How do I report satellite accumulation waste?
Waste generated in satellite accumulation areas must be reported on the Waste Generation and Management form, regardless if the waste was shipped offsite in the reporting year. If waste accumulated in satellite accumulation areas, track how much waste is generated by recording the amounts placed in the satellite accumulation drums. The total amount generated will be the sum of these recorded amounts for the calendar year.
Where do I get additional help?
For questions about the RCRA Site ID number or annual hazardous waste reporting, call DEQ’s Annual Report Hot Line in Portland at 503-229-6938 or toll free within Oregon at 1-800-452-4011, x6938.
For questions about hazardous waste regulations, call the small business technical assistance staff in the DEQ regional office nearest you:
For more information about DEQ's Land Quality programs, visit the DEQ contact page.