Louisiana RCRA Hazardous Waste Reporting

Federally, hazardous waste is regulated by the EPA under the Resource Conservation and Recovery Act (RCRA). At the state level, Louisiana hazardous waste is managed by the Louisiana Department of Environmental Quality (LDEQ). Louisiana hazardous waste regulations closely mirror federal requirements, with a few distinctions. Louisiana requires annual hazardous waste reporting through the federal RCRAInfo system. 

Understanding Louisiana Hazardous Waste/ RCRA Reporting Requirements

Who Needs to Report?

In LA, certain facilities who generate hazardous waste at or above certain thresholds are required to submit annual hazardous waste reports. Facilities who are considered large quantity generators must report annually. LA follows the federal guidelines for generator classification, meaning a facility must report if:

• The facility generates more than 1,000 kg (2,200 lbs) or hazardous waste in any given month OR
• More than 1 kg (2.2 lbs) of acutely hazardous waste in any given month
• Generate more than 100kg (220 lbs) of contaminated soil, waste, or other debris resulting from the cleanup of a spill, into or on any land or water, of any RCRA acute hazardous waste
• All facilities who generate hazardous waste in any amount must notify LDEQ of their waste generation
• The facility is a treatment, storage, and disposal facility (TSDF) that treated, stored, recycled, or disposed of RCRA hazardous wastes on-site or shipped the waste off-site to a RCRA permitted TSDF

State Listed Hazardous Waste in Louisiana 

Louisiana does not have any state specific wastes subject to RCRA reporting. Louisiana has adopted all federal waste categories and codes defined by the EPA. A full list of EPA Federal waste codes is available here .

Louisiana Generator Statuses and Requirements

Louisiana requires LQGs to submit annual waste reports each year. Federally LQGs must submit biennial reports through RCRAInfo. Louisiana uses the federal RCRAInfo system for both annual and biennial hazardous waste reports. These reports are due by March 1 each year. On RCRAInfo, LQGs will select annual reporting in odd numbered years and biennial reporting during even numbered years. All facilities that generate hazardous waste in any amount are required to notify LA of their waste activities each year by mail or electronically through RCRAInfo.

Very Small Quantity Generators (VSQG) Requirements

Federally, facilities that generate 100kg (220 lbs) or less of hazardous waste per month are considered VSQGs. VSQGs in LA are not required to submit annual reports. VSQGs are required to notify LDEQ of hazardous waste activity using form HW-1. This form should be mailed to 

Notifications & Accreditations Section Public Participation and Permit Support Division

Office of Environmental Services

Louisiana Department of Environmental Quality

Post Office Box 4313

Baton Rouge, LA 70821-4313

If a VSGQ no longer generates hazardous waste during the year, submit a No Hazardous Waste Activity Form

Small Quantity Generator (SQG) Requirements

Facilities who generate between 100 kg (220lbs) and 1,000 kg (2,200 lbs) of hazardous waste per month are considered SQGs. SQGs in Louisiana do not have to submit annual reports. SQGs are required to notify LDEQ of hazardous waste activities using form HW-1. This form should be completed and mailed to LDEQ using the address above. An SQG may choose to notify electronically by completing a Site ID form through RCRAInfo. SQGs are also required to:

• Use permitted transporters for shipments of hazardous waste
• Conduct basic employee training for employees handling hazardous waste
• Develop basic emergency response plans 
• Use Uniform hazardous waste manifests (UHWM) when shipping waste 

Large Quantity Generator (LQG) Requirements

Requirements: 

• Notify LDEQ of hazardous waste activities using form HW-1 for mail in reporting or RCRA Subtitle C Site ID form for electronic reporting
• Submit Annual Hazardous Waste Report by March 1 each year 
• Use the UHWM for waste shipments 
  • Submit UHWM to LDEQ
• Use permitted transporters for shipments of hazardous waste
• Provide formal training to all employees within 6 months of hire on waste management procedures, waste handling, and emergency response
• Have detailed contingency plans with a designated emergency coordinator. The contingency plan must include contact information, procedures for spills or other emergencies, a list of emergency equipment with locations, and evacuation routes for your facility

Examples of Facilities Subject to Waste Reporting

Below are examples of facilities in Louisiana and the industrial hazardous wastes generated that would likely trigger the need to submit an annual hazardous waste report: 

• Petrochemical and Oil Refining Facilities: spent solvents, catalysts, sludge, tank bottoms, residuals from crude oil refining and petrochemical production
• Oil and Gas Production Facilities: drilling mud, sludge, tank bottoms, spent fluids from hydraulic fracturing
• Manufacturing facilities: spent solvents, paints, coatings, heavy metals, sludges, pulping chemicals, textile dyeing waste
• Wastewater treatment plants: spent chemicals and industrial wastewater
• Research and Development laboratories/Universities: laboratory chemicals including acids and other hazardous materials, biological wastes, mercury containing materials

Hazardous Waste Manifest Requirements for Louisiana Facilities

In Louisiana, hazardous waste manifests requirements are based on federal RCRA regulations and state regulations put in place by LDEQ. Waste manifests are essential for tracking hazardous waste in a way that ensures it is properly contained, transported, and treated to protect environmental and human health. LA relies on the use of the Uniform hazardous waste manifest (EPA From 8700-22) to maintain compliance and consistency with federal standards. 

Waste manifests must include:

• EPA ID numbers of all facilities 
• Generator address and contact information
• Transporter companies with U.S. DOT descriptions
• Federal hazardous waste codes
• Waste descriptions and quantities
• Signatures from generators, transporters, and receiving facilities
• Emergency response numbers and emergency spill cleanup procedures

For Generators:

• LA requires generators to retain copies of manifests for a minimum of 3 years
• If a generator does not receive a final manifest copy from a TSDF within 45 days, they must report the manifest as missing to LDEQ
• LA encourages the use of the electronic e-Manifest system through RCRAInfo
  • If paper manifests are used, final copies must be uploaded though RCRAInfo as part of annual reporting requirements
• All generators must retain copies of manifests for a minimum of 3 years

For Treatment, Storage, and Disposal Facilities:  

• TSDFs must retain a final manifest copy for 3 years 
• TSDFs must send a copy of the final manifest to the generator 

Starting January 22, 2025: TSDFs will no longer be required to send final manifests to generators. TSDFs will upload final manifests to the federal e-Manifest system. SQGs and LQGs will be required to register for the e-Manifest system and may have to show proof of registration during inspections. 

Common Manifest Errors

• Missing information: including EPA ID numbers, container counts, and waste codes
• Inaccurate information: Transposed numbers, incorrect dates, incorrect units of measure for waste quantities.
• Failure to add all signatures and dates
• Submitting an illegible paper copy to e-Manifest 

Louisiana Electronic Waste Reporting System (RCRAInfo)

Overview of RCRAInfo

Louisiana utilizes the federal RCRAInfo system for biennial RCRA reports and state annual reports. Electronic data storage and state level reporting supports federal RCRA compliance by keeping track of certain waste streams, emergency response plans, employee training, and hazardous waste generation and storage. LQGs are required to submit federal biennial reports and must use RCRAInfo to comply with federal reporting requirements. Waste manifests uploaded and stored in RCRAInfo are accessible by fire departments and local agencies through LA. LA requires electronic reporting to ensure a unified, standardized platform that is accessible to all authorized agencies across the state. 

How to Submit a Hazardous Waste Report in RCRAInfo

Here are the key steps for using RCRAInfo Online Reporting system:

• Go to RCRAInfo  and either create a new account or sign in with your existing credentials. 
• Access the reporting module based on reporting year:
  • Odd-numbered years: Use Annual Report Module
  • Even-numbered years: Use Biennial Report Module
• Compile hazardous waste data including waste type, quantities generated, handling methods, shipments, manifests, laboratory analyses, contracts, permits, and details about disposal facilities 
• Complete all the required forms:
  • Site Identification (SI) Form: includes facility details such as EPA ID numbers, location, waste activity and contact information
  • Waste Generation and Management (GM) Form: Includes details on types and quantities of waste generated as well as how they are managed. Report both federal hazardous wastes and state-designated hazardous waste with their codes.
  • Waste Received from Off-Site (WR) Form: Information about facilities sending and receiving hazardous waste including EPA IDs, descriptions, and quantities received
  • Off-site Identification (OI) form: required when hazardous waste is shipped off-site for disposal, treatment, or recycling
• Review and submit waste reports
  • LA requires biennial report fees to be paid when reports are submitted. These fees are based on the amount of hazardous waste generated during the reporting year

Deadlines,Timelines RCRA Reporting Frequency

Annual Reporting Deadline

In LA, the RCRA reporting deadline is March 1 annually, regarding information on hazardous wastes generated by the facility in the previous calendar year

Additional Reporting Requirements (additional waste reports)

Oilfield Waste Form: In LA, facilities generated oilfield waste must submit an oilfield waste form detailing information about generation, management, and disposal of oilfield waste. This form is for reporting hazardous waste generated during oil and gas extraction operations, such as drilling fluids, produced water, and sludge.

Episodic generation: Louisiana has adopted the federal generator improvements rule, meaning LA allows for generators to temporarily exceed the waste limits for their generator category. Facilities in Louisiana must notify LDEQ at least 30 days prior to planned episodic generation events for approval, and as soon as possible following unplanned events. Failing to notify LDEQ in a timely manner after unplanned events may result in fines and civil penalties.

Tips for Effective RCRA Reporting

Maintain Continuous Records

• Continuously tracking waste generation data will help with making sure you are maintaining your generator status all year and assist in promptly identifying any changes. This is especially important because CA does not allow for episodic generation exemptions. 
• Continuously and thoroughly recording waste can help ensure your data is accurate and ready to go when the March 1st deadline comes around each year. A good rule of thumb is to have data ready to review the first week of January.
• Employee training: Federal regulations require facilities that generate hazardous waste to maintain records of their employee training. These records may need to be reported during inspections or upon request. Ensure your facility maintains up to date records of all training sessions including dates, topics covered, attendees, etc and stores these records for 3 years to ensure compliance. 

Understand State-Specific Reporting Requirements

Louisiana requires all generators, regardless of generator status, to notify LDEQ of their hazardous waste activities. Generators may notify LDEQ via paper forms using HW-1 form, or electronically using a Site ID form through RCRA Info.

• LQGs in LA are required to submit hazardous waste reports through RCRAInfo each year

Keep Copies of All Submitted Reports

All annual reports should be retained for a minimum of 3 years. Once an annual report is submitted, it can be exported as a PDF, CSV, or Excel file using the following directions:

1. Log into the RCRAInfo website using your user credentials.
2. From the dashboard, select “Annual Report” (or biennial depending on the year) and locate your submitted report in the list of submissions.
3. Click on the specific report and select “export” 
4. Review the results onscreen and click the export button. Choose the format you prefer and save your file to your computer. 

Common Mistakes in RCRA Reporting and How to Avoid Them

Incorrectly Estimating Quantity of Reportable Wastes

Reporting incorrect waste quantities or generator status can be due to events of underreporting to avoid reaching large quantity generator status and over-reporting due to data management errors

Tips:

• Create standardized reporting checklists to ensure accurate information
  • Consider electronic tracking or digital software to automatically calculate quantities based on generation and shipments 
• Maintain up to date and accurate logs of waste generation and disposal all year long

Failure to Report All Hazardous Wastes

Failing to report all hazardous wastes can occur for a number of reasons, including misidentification or under-classification of waste streams. This can happen when a facility overlooks smaller waste streams, fails to recognize mixtures of hazardous waste with nonhazardous waste, or relies on outdated waste determination rules. Failing to report all waste can lead to underreporting, misrepresentation generator categories, and issues of non-compliance. 

Tips:

• Conduct regular waste stream inventories 
• Regularly update waste determinations
• Use a digital waste management tracking system to reduce errors and improve record keeping
• Consult with environmental experts 

Failing to Keep Up-To-Date with Changes in Regulations

Failing to keep up with changes in regulations can be due to a number of factors. Facilities may lack designated staff members dedicated to tracking regulatory updates, incorrectly assume that long-standing waste management practices remain compliant, or fail to monitor changes from both the EPA anD LDEQ

Tips:

• Assign a designated staff member or team to monitor current waste regulations
• Subscribe to updates from federal agencies and local EHS groups 
• Conduct annual compliance audits
• Implement software solutions to track hazardous waste regulations and notify of updates 

Late and Missed Submissions

All annual reports must be submitted and paid for by March 1 each year. Late submissions will be met with late fees imposed by LDEQ. Missed reports will lead to a Notice of Violation, fees, and increased likelihood of frequent inspections and audits. Contact LDEQ if an extension is needed.

Tips:

• Create a shared compliance calendar and set reminders well in advance
• Start compiling hazardous waste data and facility information early (by January at the latest) to avoid last-minute errors
• Use a centralized digital filing system so data can be easily and readily accessed

Penalties for Non-Compliance with RCRA Reporting in Louisiana 

Potential Fines and Legal Consequences

Non-compliance in Louisiana can lead to penalties, including civil and criminal fines. Penalties and fines are imposed by the LDEQ and the EPA and are based on the nature, extent, gravity, and circumstances of the violation. Examples of potential consequences include:

• $25,000 per day for failing to report information about generation, storage, or use of hazardous waste
• Up to $50,000 per violation relating to missed annual reports, missed manifest submissions, or missed notifications of hazardous waste activity 
• Criminal penalties for knowingly engaging in illegal disposal or treatment of hazardous waste
• In 2017, a manufacturing company regularly sent hazardous waste to a TSDF without a permit. The company was fined $1,398,000 as a civil penalty for this violation and was subject to additional reporting requirements including the waste disposal methods every 6 months