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Contact information
For information about managing hazardous waste, contact:
Mike Ellenbecker
Hazardous waste program coordinator

Management of hazardous waste in Wisconsin

Hazardous waste is a special class of solid waste that must be managed properly to protect human health and the environment. Federal and state laws regulate how businesses, institutions, governments and other non-households must manage this waste. These regulations do not cover most hazardous waste generated by households, but household hazardous waste should be managed carefully as well.

In Wisconsin, there are currently about 11,000 businesses, schools and government institutions that generate varying quantities and types of hazardous waste. The number of hazardous waste generators and the quantity of hazardous waste generated has declined in recent years, mostly due to successful waste minimization efforts, the economy and the cost of disposal.

Determining if your business generates hazardous waste

State and federal law require businesses and institutions to determine if their waste is hazardous. A business can determine if it generates hazardous waste by carefully reviewing ch. NR 661, Wis. Adm. Code, and by answering the following questions.

  1. Is the material solid waste?
  2. Is it excluded from the hazardous waste rules?
  3. Is it a listed or characteristic hazardous waste?
  4. Is it a mixture containing hazardous waste, or is it derived from hazardous waste?

Waste Determinations and Recordkeeping (WA-1152) [PDF] can help you with the hazardous waste identification process. If your business generates hazardous waste you must determine the quantity you generate in any given month and establish your generator status.

Hazardous waste generator classifications and requirements

If your business or institution generates hazardous waste, you must comply with certain requirements, depending on the quantity of hazardous waste you generate during any given month. All hazardous waste generators must make a waste determination and properly dispose of their hazardous waste. Additional requirements apply based on the generator classification.

There are three hazardous waste generator classifications:

  1. very small quantity generators (VSQG);
  2. small quantity generators (SQG); and
  3. large quantity generators (LQG).

The table below lists generation and storage limits for each generator classification. As a reference, 220 pounds equals approximately half of a 55-gallon drum.

Generation and storage limits for hazardous waste generator classifications
Monthly generation limit of non-acute hazardous waste <220 pounds <2,205 pounds

No limit

Monthly generation limit of acute (P-listed) hazardous waste <2.2 pounds <2.2 pounds No limit
On-site accumulation limit 2,205 pounds 13,230 pounds No limit

Ch. NR 662, Wis. Adm. Code [PDF exit DNR] has more information on the generator categories and the requirements that apply.

DNR notification and EPA ID number

Large quantity and small quantity generators, very small quantity generators that choose to manifest their waste, and hazardous waste treatment and storage facilities must notify the DNR of their hazardous waste activity and obtain an EPA ID number. To apply for an EPA ID number, you must file a Notification of Regulated Waste Activity (EPA Form 8700-12).

Hazardous waste annual report to the DNR

Small and large quantity generators must file an annual report with the DNR. To prepare for your annual report and to ensure compliance with hazardous waste regulations, records of waste determinations, generation quantities, transport of waste and final disposal should be maintained.

Transporting hazardous waste

A transporter is anyone who transports hazardous waste off-site by air, rail, highway or water. To transport hazardous waste in Wisconsin that was generated by either large or small quantity generators, you must have both a valid EPA ID number and a hazardous waste transportation service license issued by the DNR. Hazardous waste transportation requirements are in ch. NR 663, Wis. Adm. Code.  A very small quantity generator can self-transport hazardous waste without a transportation license or a hazardous waste manifest. If a very small quantity generator chooses to manifest its waste for transport, it must obtain an EPA ID number from the DNR.

The following guidance document has instructions for how to obtain an EPA ID number and hazardous waste transportation license, along with information on the required fees, manifest requirements and additional transporter requirements:

Waste facility and transporter licenses has additional information on obtaining transporter licenses and lists of currently licensed hazardous waste transporters.

Treatment, storage and disposal of hazardous waste

Facilities that treat, store or dispose of hazardous waste, known as TSDFs, must be licensed by the DNR, unless the activity is specifically exempt from the licensing requirement.

Wisconsin is home to 12 licensed hazardous waste management facilities, some of which are licensed to store or treat only the hazardous waste they generate. Commercial TSDFs manage hazardous waste generated by businesses and institutions in Wisconsin, as well as potentially from other states or foreign countries. Commercial TSDF hazardous waste management activities may include recycling/reclaiming solvents and mercury, fuel blending for energy recovery and treatment to facilitate disposal. There are no operating hazardous waste disposal facilities (landfills) in Wisconsin.

Hazardous wastes with reduced regulations

There are several waste streams regulated under the hazardous waste ch. NR 600, Wis. Adm. Code, series that have alternative management options. When these waste streams are managed in accordance with the outlined requirements, they are subject to reduced regulation. This is to facilitate the diversion of household hazardous waste, the recycling of universal wastes, and the recovery and reuse of used oil.

Disposal options for household hazardous waste

Residential hazardous waste is not subject to Wisconsin's hazardous waste rules unless it is segregated from normal household trash for management. However, households should understand the types of waste they have and how to properly manage it to protect the safety of family members and pets and protect the environment.

Facilities that collect household hazardous waste must follow the collection facility requirements in ch. NR 666, subch. HH, Wis. Adm. Code [PDF exit DNR].

Streamlined requirements for universal waste

To encourage and facilitate recycling, Wisconsin's universal waste regulations reduce the hazardous waste management standards for Wisconsin's designated universal waste, which includes hazardous waste batteries, pesticides, mercury-containing equipment, lamps and antifreeze.

The universal waste regulations govern the collection and management of these widely generated wastes and provide an alternative set of requirements that reduces the regulatory burden by allowing longer storage of these wastes and reduced recordkeeping.

Disposal options for used oil

Both state and federal agencies recognize the value of used oil for uses such as producing fuels and lubricants, and also its potential threat to the environment if mismanaged. Wisconsin has banned used oil and oil filters from landfill disposal.

Businesses and institutions that are required to follow the used oil management standards in ch. NR 679, Wis. Adm. Code, include:

  • generators;
  • collection centers and aggregation points;
  • transporters and transfer facilities;
  • processors and re-refiners;
  • burners; and
  • fuel marketers.

The following guidance document has more information on the requirements:

The DNR recommends that household do-it-yourselfers and small farmers store used oil in closed containers that are in good condition and labeled “used oil,” and take their used oil to a used oil collection center, a community collection site, or a retail store that accepts used oil.

Last revised: Thursday August 22 2019