Business Hazardous Waste

Fairfax County Government Conditionally Exempt Small Quantity Generator (CESQG) - Business (Commercial) Hazardous Waste Disposal Program

Residents Recycling and Disposal Center at the I-66 Transfer Station

Fairfax County Household Hazardous Waste Division
Household Hazardous Waste Disposal Facility
I-66 Transfer Station
4618 West Ox Road, Fairfax, VA 22030
Follow the Household Hazardous Waste signs.
Daniel Brooks: 703-803-9614, TTY 711 or 703-803-6158, TTY 711

Save money on safe, legal hazardous waste disposal!
No recordkeeping requirements!
Six disposal events scheduled in 2016!

2016 CESQG Event Dates:

  • Wednesday, January 13, 2016
  • Wednesday, March 2, 2016
  • Wednesday, May 4, 2016
  • Wednesday, July 13, 2016
  • Wednesday, September 14, 2016
  • Wednesday, November 2, 2016

We've recently expanded the number of CESQG events from three to six for calendar year 2016 - twice as many opportunities to safely dispose of hazardous material! Events run 9 a.m. to 2 p.m., rain or shine. CESQG events will be conducted as previously outlined except in the rare event that the I-66 Transfer Station facility should close due to severe inclement weather or emergency. Business/commercial waste may only be disposed of on a scheduled business disposal day.

Business (Commercial) Hazardous Waste

Businesses or Fairfax County Government agencies that generate small quantities of hazardous waste may qualify for a special, county managed program that provides a legal and affordable solution to hazardous waste disposal. The benefit of the program is that it offers prices well-below the normal cost of disposing of hazardous waste directly with a hazardous waste disposal contractor. Additionally, the program negates the burden of having to maintain painstaking recordkeeping requirements. The county calls these qualified participants Conditionally Exempt Small Quantity Generators (CESQGs).

If you own a business, you probably have hazardous materials requiring proper disposal. Not sure?

Do you have any items that match these hazardous characteristics?

  • Ignitable (Flammable or Combustible)
  • Toxic (Poisonous)
  • Corrosive
  • Reactive

Do you have any of these types of items (just to name a few)?

  • Batteries (other than alkaline)
  • Fluorescent Light Bulbs or Tubes
  • Mercury Containing Articles
  • Light Ballasts (PCBs)
  • Pesticides, Insecticides, or Herbicides
  • Solvents
  • Paint
  • Degreasers
  • Cleaning Products
  • Aerosol Cans

Full list of accepted materials

What is a Hazardous Waste Generator?

A generator is any person who produces a hazardous waste as listed or characterized in part 261 of title 40 of the Code of Federal Regulations (CFR). Recognizing that generators produce waste in different quantities, the Environmental Protection Agency (EPA) established three categories of generators in the regulations:

The volume of hazardous waste each generator produces in a calendar month determines which regulations apply to that generator. Below is more information about each category of generator.

EPA Categories of Hazardous Waste Generators

Hazardous Waste Generator Regulatory Summary (table). This link provides a FULL summary of the requirements for each class of hazardous waste generators.

What is a Conditionally Exempt Small Quantity Generator or CESQG?

Conditionally Exempt Small Quantity Generators (CESQGs) generate 100 kilograms (220.46 lbs.) or less per month of hazardous waste or one kilogram (2.2 lbs.) or less per month of acutely hazardous waste. Requirements for CESQGs include:

  • CESQGs must identify all the hazardous waste generated.
  • CESQGs may not accumulate more than 1,000 kilograms of hazardous waste at any time.
  • CESQGs must ensure that hazardous waste is delivered to a person or facility who is authorized to manage it.

See 40 CFR §261.5 for a complete description of the CESQG regulations.

Additionally, most states are authorized to implement the Resource Conservation and Recovery Act (RCRA) program. State generator categories can be different than the federal categories. Please see the differences in hazardous waste generator categories table. Click on the state of Virginia to see the state's regulatory requirements. (The state of Virginia regulatory requirements are the same as the federal standards.)

How Can My Business Participate in the CESQG Program?

Five simple steps to participate in the CESQG program:

  1. Waste Identification
  2. One-time free enrollment including notarized waiver
  3. Secure materials for safe transport
  4. View or print the CESQG brochure
  5. Show up with your required paperwork

1.    First determine if you have met the requirements to qualify as a CESQG by making a waste identification.

The hazardous waste identification process is the crucial first step in the hazardous waste management system. Correctly determining whether a waste meets the RCRA definition of hazardous waste is essential to determining how the waste must be managed. The waste generator has responsibility for determining if a waste is a RCRA hazardous waste. (See: 40 CFR 262.11) The HWID process consists of four questions:

  1. Is the material a solid waste? (See: 40 CFR Part 261.2)
  2. Is the waste specifically excluded from RCRA? (See: 40 CFR Part 261.4)
  3. Is the waste a listed hazardous waste? (See: 40 CFR Part 261.30)
  4. Does the waste exhibit a characteristic of hazardous waste? (See: 40 CFR Part 261.20)
  5. View the EPA's steps for identifying hazardous waste. Still note sure? Call the Household Hazardous Waste Facility a call at 703-803-9614, TTY 711, 703-803-6158, TTY 711 or send an email.

2.    Start the process for a ONE-TIME sign-up for enrollment:

(There is no fee to sign up. Enrollment is FREE!)

  • Prior to the event, print a copy of our CESQG Liability of Waiver form. The liability of waiver form will need to signed by the owner, generator, or acting agent of the participating business. The signed copy of the liability of waiver form will then need to be Notarized. This is a one-time requirement for participation. After the initial sign-up, this step will not be necessary for future disposal visits.

    If you are unable to get the signed liability of waiver notarized prior to arrival, a notary may be available during the event. We cannot guarantee that this will always be the case and we strongly recommend that you inquire prior to your arrival.

    Should a program participant arrive without having a signed/notarized liability of waiver form, participation will be contingent upon an onsite notary being available for assistance. There would be no charge for the notary if available; however, this may cause a slight delay in the processing and disposal of your waste.

  • Upon arrival at the CESQG event, you must bring with you a copy of your Business, Personal Property, State, or County Business License to show as proof that your business is located in Fairfax County (including cities or towns located within the county).

3.    Secure all materials for safe transport.

  • Prior to arrival, place all chemicals or other items requiring disposal in secure containers, boxes, or drums. We cannot accept any drums larger than five-gallon increments. For example, a full 55-gallon drum would need to be emptied prior to the event and brought in 11 x 5 gallon containers.
  • Make sure that all items are labeled properly for identification. If there are multiple contaminants mixed together such as previously consolidated solvents, list all of the used (spent) chemicals or constituents associated with the mixture to ensure proper disposal.
  • Ensure all containers are secured tightly including lids or caps to prevent leakage or spills from occurring.

4.    Print off a copy of our online CESQG - Business Hazardous Waste Disposal Program brochure. It is a quick reference pamphlet outlining some of the important steps required for participation in our program. It also provides a price list for commonly disposed of items.

5.    Show up with your required paperwork.

What if I exceed the amount of hazardous waste allowed under the CESQG statute?

If you exceed the amount of waste allowed under the program requirements, your business will not be eligible to participate in the Fairfax County, Virginia CESQG disposal program during any period that it does not meet the conditions of a Conditionally Exempt Small Quantity Generator under the Virginia Hazardous Waste Management Regulations (VHWMR) and provisions in that section adopted by reference from 40 CFR Part 261.5.

If a CESQG exceeds the allowable generation rate in a calendar month due to a unique occurrence or an unforeseeable/infrequent event, such as environmental remediation, it may be an episodic generator. If it becomes a repeated occurrence, changing your generator status will be required. Until the waste is removed from the site, you must comply with the more stringent regulations associated with being a small or large quantity generators, depending upon the amount of hazardous waste generated. The business can return to CESQG status after the waste is transported off site for disposal and as long as it does not generate more than 220 pounds in any one calendar month during the next 12 months.

For more information about this matter, see the Virginia Department of Environmental Quality's requirements for CESQGs. If you fail to meet the participation requirements of a CESQG, you may utilize the services of a hazardous waste disposal contractor and transporter. Find hazardous waste disposal contractors and transporters.

What Hazardous Materials (Substances) are Accepted & What is the Cost for Disposal?

A hazardous substance exhibits any of the four characteristics below (40 CFR Part 261, Subpart C):

  • Ignitability
  • Corrositivity
  • Reactivity
  • Toxicity

*Materials that are accepted at No-Charge.
**Call for cylinder size specifications and pricing.

If item(s) are not listed, please contact the Fairfax County Household Hazardous Waste Division at 703-803-9614, TTY 711, 703-803-6158, TTY 711 or email for disposal questions and pricing.

Disposal Pricing:

Fees vary depending upon the quantity and type of material. Refer to our price list below for more information. Call for pricing inquiries about specialty disposal items or items not found listed in the attached price list.

Pricing quotes can be obtained by calling at least two weeks in advance of an upcoming event on the premise that a detailed, itemized inventory is provided, including types and sizes of all containers. Any deviation from the reviewed and approved quote will result in pricing changes.

All payment for disposal services rendered is due upon arrival. A copy of your receipt will be provided to you by Fairfax County Government upon completion of the service. Businesses paying by credit card (Visa or MasterCard) may also have the option to receive a receipt emailed to them electronically.

Acceptable methods of payment:

  • Cash
  • Make checks payable to Director of Finance, Fairfax County Government
  • Credit Card (Visa or MasterCard)
  • Intercompany Agency (Fairfax County Government Agencies only). Fairfax County Agencies wishing to pay via intercompany agency must provide a Cost Center # and Fund Number. Failure to do so will disqualify the agency from paying in this manner.

Do Non-Hazardous Waste Items Count Against my Generator Status & What are Some Examples of Each?

Non-hazardous wastes DO NOT count against your CESQG generator status. There is no limit to the amount of non-hazardous waste you can dispose of in any given month.

Examples of Non-Hazardous Waste Include:

  • Alkaline Batteries (Trash)
  • Antifreeze
  • Cooking Oil
  • Diesel
  • Halogen Light Bulbs
  • Hydraulic Oil
  • Incandescent Light Bulbs
  • Kerosene
  • LED Light Bulbs
  • Latex Paint
  • Motor Oil
  • Non-PCB Ballasts
  • Pneumatic Oil
  • Power Steering Fluid

Do Universal Waste Items Count Against my Generator Status & What are some Examples of Each?

Universal waste is a subset of hazardous waste and contains mercury, lead, cadmium, copper and other substances hazardous to human and environmental health. Universal wastes are generated from a wide variety of sources (i.e., individuals, government agencies, hospitals, businesses, etc.) in a variety of settings, not just in traditional industrial settings.

In 1995, U.S. EPA developed an alternate, streamlined management program to encourage the collection and recycling of these commonly generated hazardous wastes. The federal universal waste regulations can be found in 40 CFR Part 273. Virginia Department of Environmental Quality has adopted the federal universal waste regulations by reference with a few additional requirements. The DEQ regulations can be found at 9VAC20-60-273.

Managing qualifying hazardous wastes as universal waste is optional. Generators have the choice to manage hazardous wastes that fit into the categories of universal waste as universal wastes in Part 273 or under the full set of hazardous waste regulations. For a full understanding of the regulatory requirements of universal waste, read VADEQ Universal Waste Management & Regulations.

Examples of Universal Waste Include:

  • Batteries (Lead Acid)
  • Batteries (NiCad/NIMH)
  • Batteries (Lithium/Lithium Ion)
  • Batteries (Mercury)
  • Batteries (Silver Oxide)
  • Fluorescent Light Bulbs (CFLs) or Tubes (Mercury)
  • Mercury Containing Equipment
  • Mercury Thermostats
  • Metal Halide Bulbs (Mercury)
  • PCB Ballasts
  • Pesticides
  • Sodium Vapor Bulbs (Mercury)

What Items are NOT Accepted?

  • Ammunition
  • Compressed Gas Cylinders (Other than Those Listed under Acceptable Materials)
  • Explosives
  • Medical or Biological Waste
  • Radioactive Materials

Do the Regulations that Apply to Household Hazardous Waste Collections also Apply to Collections of Conditionally Exempt Small Quantity Generator (CESQG) Hazardous Waste?

No. Although the generator of CESQG waste is exempted from certain provisions of the hazardous waste management regulations, the waste itself is not excluded from regulation as a hazardous waste. Hence, the requirements that apply to household hazardous waste collections are different from those that apply to CESQG waste collections. CESQG waste must be managed as hazardous waste under regulations established in § 9VAC20-60-261 of the Virginia Hazardous Waste Management Regulations and provisions in that section adopted by reference from 40 CFR Part 261.5. Read this guidance document that provides a complete explanation of the regulations pertaining to CESQG waste collection programs with a focus on those operated by local governments and municipalities.

Who Should I Contact to get More Information?

Household Hazardous Waste facility: 703-803-9614, TTY 711, or 703-803-6158, TTY 711

Fairfax County Solid Waste Management Program: 703-324-5230, TTY 711

Email Daniel Brooks

See Also:
The Know Toxics Program
Household Hazardous Waste

Contact Fairfax County: Phone, Email or Twitter | Main Address: 12000 Government Center Parkway, Fairfax, VA 22035
Technical Questions: Web Administrator

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