How to Use Episodic Events to Manage Hazardous Waste and Stay RCRA Compliant

Many industrial facilities end up with hazardous waste they don’t know what to do with—old drums of chemicals, outdated pails of raw materials, or leftover products that have been sitting unused for years. These materials can create serious RCRA compliance issues if they’re not managed properly.

The good news? Facilities may be able to avoid unnecessary costs and regulatory burdens by using an episodic event to clean out these materials.

What Is an Episodic Event Under RCRA?

The U.S. Environmental Protection Agency (EPA) created the episodic generation rule to give businesses flexibility in handling one-time or short-term hazardous waste cleanouts.

An episodic event is a planned or unplanned activity that generates more hazardous waste than a facility normally produces. Instead of automatically bumping a facility into Large Quantity Generator (LQG) status, the EPA allows Very Small Quantity Generators (VSQGs) and Small Quantity Generators (SQGs) to temporarily exceed their limits—without permanently changing their generator category.

This is a powerful compliance tool for facilities that only occasionally generate extra waste, such as during plant cleanouts, tank maintenance, or chemical inventory reduction.

Why Should Facilities Consider an Episodic Event?

When we visit industrial sites, we often see:

  • Forgotten containers of old or unknown chemicals
  • Tanks overdue for a full cleanout
  • Surplus or expired raw materials taking up space

Not only do these situations increase regulatory risk, but they also create safety hazards for employees and take up valuable storage space.

An episodic event provides the opportunity to:

  • Safely dispose of outdated or unused chemicals
  • Conduct a facility-wide hazardous waste cleanout
  • Perform a chemical inventory and eliminate materials you no longer need

Benefits of an Episodic Event

  • Stay in compliance – Avoid triggering LQG status unnecessarily
  • Reduce liability – Minimize risks associated with old or unstable chemicals
  • Save money – Manage waste efficiently without taking on LQG costs and requirements
  • Improve operations – Free up storage space and keep your chemical inventory up to date

How to Plan for an Episodic Event

Facilities must notify regulatory agencies in advance (or within a set timeframe for unplanned events), follow specific waste management requirements, and complete disposal within strict deadlines.

Because of these rules, it’s best to work with an experienced environmental consultant to ensure your episodic event is done safely and in full compliance with EPA and state regulations.