After completing the  hazardous waste determination  as required by USEPA regulations at 40 CFR 262.11, the most fundamental responsibility of the generator of a waste is to count the hazardous waste it generates each month and determine its hazardous waste generator category. 

From the Federal Register publication of the final rule (81 FR, 11.28.16, 85755):

A generator must correctly count the quantity of hazardous waste that it generates in order to determine its generator category.

Despite its importance, the requirements for counting hazardous waste and determining generator category were not presented in a clear and distinct manner. That problem was corrected by the  Generator Improvements Rule . The purpose of this article is to identify and explain the requirements of 40 CFR 262.13 for the counting of hazardous waste and the determination of hazardous waste generator category as revised by the Generator Improvements Rule.


Important note: As 40 CFR 262.13(e) indicates, after a generator has counted its hazardous waste and determined its generator category it must comply with the applicable regulations for that category. If you have any questions about the hazardous waste determination, determining your hazardous waste generator category, or any of the responsibilities of a hazardous waste generator. Contact me for further information .