Minnesota RCRA Hazardous Waste Reporting
Minnesota hazardous waste reporting is regulated by the Minnesota Pollution Control Agency (MPCA) and county agencies. The goal of the state program is to provide “cradle to grave” management of hazardous wastes to ensure the protection of the environment and human health. Federally, hazardous waste is regulated under the Resource Conservation and Recovery Act (RCRA). Compliance with state and federal RCRA regulations is required for facilities that generate and dispose of hazardous waste at certain thresholds. At the federal level, RCRA requires a biennial report to be submitted by large quantity generators of hazardous waste. Minnesota has more stringent reporting requirements, including increased frequency, state-specific hazardous wastes, and county variations.
Understanding Minnesota Hazardous Waste/ RCRA Reporting Requirements
Who Needs to Report?
In Minnesota, generators and treatment, storage, and disposal facilities (TSDFs) are required to report their hazardous waste activities. Reporting requirements are based on activities and generation quantities. Generators in the Greater Minnesota area are required to submit reports to MPCA, while generators in the Twin Cities metropolitan area are required to report to their county. The annual report in Minnesota is known as the Hazardous Waste Generator License Application. This application is due each year by August 15th for generators outside the Twin Cities metropolitan area, December 15th for generators in Hennepin County, and January 31st for generators in all other counties in the Twin Cities metropolitan area The application details hazardous waste activities from the previous year. The following facilities must report annually:
- Facilities that generate more than 100 lbs of reportable wastes
- Treatment, storage, and disposal facilities (TSDFs)
- In addition to annual reports, Large Quantity Generators must submit federal biennial reports to the EPA every 2 years.
State-Listed Hazardous Waste in Minnesota
Minnesota has state-specific wastes that are considered hazardous. These wastes are given state-specific waste codes and are subject to all generation, storage, shipping, and disposal regulations. In addition to the federal hazardous waste characteristics, Minnesota also has a lethal category for categorizing wastes. Some of these wastes include:
- MN01: Poisons such as cyanide-contaminated wastes
- MN02: sulfide compounds
- MNO3: toxic organic compounds such as pesticides or solvents
- MN07: pharmaceuticals classified as lethal due to high toxicity
- Certain counties in MN also have additional waste codes. For example, Washington County has several waste codes specific to the county, including:
- WC01: Used Oil
- WC02: Used Oil Filters
- WC03: Oil rags/sorbent
More information on classifying hazardous wastes in MN, along with waste codes can be found here
Minnesota Generator Statuses and Requirements
Minimal Quantity Generator (MiniQG) Requirements
In MN, a MiniQG generates less than 100 lbs of hazardous waste and no acute hazardous waste per year. MiniQGs must follow all requirements for VSQGs, but do not have an annual license fee. MiniQGs are not applicable in all Metro counties. MiniQGs do not submit reports each year, but still have requirements to stay in compliance:
- Obtain a Hazardous Waste ID Number (HWID) using MPCA’s online e-Services. Do not use EPA form 8700-12
- Submit a Hazardous Waste Generator License application every 3 years
- Ensure storage does not exceed 2,200 lbs of hazardous waste on-site at any time
- MiniQGs have several options to dispose of waste including:
- Ship hazardous waste to a permitted TSDF or recycling facility
- Self-transport waste to a Very Small Quantity Generator Collection Program
- Self-transport to a licensed collection site
- Self-transport to a Household Hazardous Waste Collection Program
Very Small Quantity Generators (VSQG) Requirements
VSQGs generate less than 220 lbs of hazardous waste and less than 2.2 lbs of acutely hazardous waste per month VSQs have several requirements, including:
- Obtain a HWID using MPCA’s online e-Services, Do not use EPA form 8700-12
- Submit a Hazardous Waste Generator License Application by August 15th each year for generators outside of the Twin Cities metropolitan area
- Submit a Hazardous Waste Generator License Application by December 15th to generators within Hennepin County and by January 31st each year for generators in all other counties of the Twin Cities metropolitan area
- Ensure storage does not exceed 2,200 lbs of hazardous waste on-site at any time
- Store hazardous waste in appropriate containers
- Use Uniform Hazardous Waste Manifests for waste shipments
- Maintain basic emergency response procedures and equipment, including alarms, fire protection, and spill containment equipment
Small Quantity Generator (SQG) Requirements
SQGs generate between 220 and 2,200 lbs of hazardous waste and less than 2.2 lbs of acutely hazardous waste per month. SQGs have several requirements, including:
- Obtain a HWID using MPCA’s online e-Services, Do not use EPA form 8700-12
- Submit a Hazardous Waste Generator License Application by August 15th each year for generators outside of the Twin Cities metropolitan area
- Submit a Hazardous Waste Generator License Application by December 15th to generators within Hennepin County and by January 31st each year for generators in all other counties of the Twin Cities metropolitan area
- Waste determination: keep detailed records of how waste determinations are made
- Ensure storage does not exceed 6,000 lbs or occur for longer than 180 days
- Store hazardous waste in appropriate containers
- Post emergency contact information and procedures for spill responses
- Name an emergency coordinator who is available 24 hours a day to respond to emergencies
- Train employees who:
- generate or handle waste
- Prepare hazardous waste records such as manifests and inspection logs
- Are designated spill response teams
- Are named emergency coordinators
- Keep all training records for 3 years
- Only use permitted TSDFs
- Use Uniform Waste Manifests for waste shipments
- Keep copies of manifests for a minimum of 3 years
- Submit a Land Disposal Restriction (LDR) Notification with each waste shipment
Large Quantity Generator (LQG) Requirements
LQGs generate 2,200 lbs or more of hazardous waste or more than 2.2 lbs of acutely hazardous waste per month. LQGS have several requirements, including:
- Obtain a HWID using MPCA’s online e-Services, Do not use EPA form 8700-12
- Submit a Hazardous Waste Generator License Application by August 15th each year for generators outside of the Twin Cities metropolitan area
- Submit a Hazardous Waste Generator License Application by December 15th to generators within Hennepin County and by January 31st each year for generators in all other counties of the Twin Cities metropolitan area
- Waste determination: keep detailed records of how waste determinations are made
- Not store waste on-site for more than 90 days without a permit
- Store hazardous waste in appropriate containers
- Use the Uniform Hazardous Waste Manifest for all waste shipments
- Keep copies of manifests for a minimum of 3 years
- Submit a Land Disposal Restriction (LDR) Notification with each waste shipment
- Develop and maintain a formal contingency plan addressing emergency response procedure
- Provide copies to local emergency response agencies such as police and fire departments, ambulance services ,and hospitals
- Provide formal training to all employees within 6 months of hire who:
- Generate or handle waste
- Prepare hazardous waste records such as manifests and inspection logs
- Are designated spill response teams
- Are named emergency coordinators
- Keep all training records for 3 years
- Complete weekly inspections of waste storage areas and maintain records of inspections
- Submit federal biennial hazardous waste reports every 2 year, using the EPA’s electronic RCRAInfo portal
Key Points: It is important to remember that MN hazardous waste requirements can vary by county. Generators in the Metro area (Anoka, Carver, Dakota, Hennepin, Ramsey, Scott, and Washington counties) have county authorities who regulate hazardous waste. License applications for these counties are submitted through county portals and/or paper. Deadlines for hazardous waste generator applications by county. Additional regulations can vary by county, so consult local county offices to ensure requirements are being met.
| Region/County |
Application/renewal deadlines |
Additional requirements |
| Statewide (excluding Metro counties) |
August 15th via MPCA e-Service |
|
| Anoka County |
March 31st |
Used Oil Generators must apply for licenses |
| Carver County |
January 31st |
Additional forms for VSQGs
MN Department of Revenue Form |
| Dakota County |
January 31 |
Separate forms for MiniQGs
Additional forms for VSQGs |
| Hennepin County |
December 15 |
MiniQG licenses are renewed automatically every 5 years
Complete and mail specific forms for each waste stream
Updates made via the Hennepin County Hazardous Waste portal |
| Ramsey County |
January 31 |
A one-time license for one-time generation needed
Must submit a management plan for each waste stream |
| Scott County |
January 31 |
Additional VSQG forms |
| Washington County |
January 31 |
Must submit a waste management plan for each waste stream
County-specific waste codes for oil waste |
Examples of Facilities Subject to Waste Reporting
Here is a list of common facilities in MN and the wastes they generate that would likely trigger the need to submit a hazardous waste license application:
- Manufacturing: F001 and F002 solvents, wastewater treatment sludges with heavy metals, paint, and coating wastes, spent solvents from cleaning processes
- Hospitals: pharmaceutical wastes, chemotherapy drugs, mercury-containing devices, lethal drug waste, solvent-contaminates wipes and cleaning products
- Automotive manufacturing: paint booth sludges containing VOCs, solvent-contaminated wipes, spent coolants and oils, waste adhesives and sealants
- Energy production: lead-acid batteries, PCB-containing materials, waste oils, contaminated soil from spills
Hazardous Waste Manifest Requirements for Minnesota Facilities
All generators are required to use hazardous waste manifests for waste shipments, with few exceptions such as self-transported VSQG waste to a collection program. All shipments must use the federal Uniform Hazardous Waste Manifest (EPA Form 8700-22). In MN, manifests may be paper copies or electronic through the EPA e-Manifest system. The following requirements are administered by MPCA, the metropolitan counties, and the EPA.
Waste manifests must include:
- Generator information including name, address, and EPA ID
- Transporter details including ID numbers and U.S. DOT descriptions
- TSDF information including name, address, and EPA ID
- Waste descriptions
- Name, hazard class, EPA waste codes, quantities, and container information
- Special handling instructions
- Signatures from generators, transporters, and final receiving facilities
- Emergency response numbers and emergency spill cleanup procedures
For Generators:
- MN encourages the use of the federal e-Manifest system for the submission and tracking of manifests
- If paper manifests are used, TSDFs upload the final copy to the e-Manifest system. Generators must be registered with the e-Manifest system and able to access electronic manifests during inspections. Starting January 22, 2025, federal regulations will require all SGQs and LQGs to register for the e-Manifest system
- Paper copies must be stored for at least 3 years
- Exception reporting updates starting January 22, 2025:
- If a signed copy of the final manifest has not been submitted to e-Manifest within 45 days of acceptance, LQGs must inquire with the TSDF on the status of the waste
- If a signed copy has not been submitted within 60 days, LQGs and SQGs must submit an exception report with MPCA
- Starting December 1, 2025, exception reports must be submitted electronically through e-Manifest
For Treatment, Storage, and Disposal Facilities:
- The UHWM must accompany waste throughout its shipment and treatment process
- Must upload a copy of the signed final manifest to e-Manifest within 35 days.
- Generators can access final manifests through RCRAInfo.
- Must maintain copies of manifests for a minimum of 3 years.
- Unmanifested Waste Reports: If a TSDF accepts hazardous waste without a manifest, a report must be submitted to the MPCA within 15 days of accepting the waste. This report includes information about the facility, the waste type and quantity, method of treatment, storage, and disposal, and an explanation for why the waste was unmanifested
- Discrepancy Reports: If a TSDF operator determines a discrepancy in quantities or types of waste, they must first attempt to resolve it with the generator within 15 days of the incident. If it is not resolved within 15 days, TSDFs must submit a report to IL EPA detailing the discrepancy, copies of waste manifests, and attempts to resolve the issue
Common Manifest Errors
- Incomplete or incorrect generator information
- Improper waste descriptions
- Missing signatures
- Failing to retain copies
- Missing land disposal restriction notifications
- Tips to avoid errors in manifests:
- Provide regular training for staff responsible for completing manifests
- Double-check information such as waste codes, DOT names, hazard classes, and ID numbers
- Use the EPA e-Manifest system to reduce paperwork and fix errors quickly
Minnesota Electronic Waste Reporting System (e-Services)
Overview of e-Services
Minnesota utilizes the state-based e-Services portal for electronic reporting (excluding Metro counties). Metropolitan counties submit annual reports via electronic county portals or paper (below). Minnesota encourages electronic reporting to ensure a unified, standardized platform accessible to all authorized agencies across the state
| Region/County |
Reporting System |
Forms (if applicable) |
| Statewide (excluding Metro counties) |
e-Services |
|
| Anoka County |
Anoka County Environmental Services portal or email
hazardouswaste@co.anoka.mn.us
|
Anoka County Application |
| Carver County |
Email or mail:
hazardouswaste@co.carver.mn.us
Carver County Environmental Services
600 East 4th St
Chaska, MN 55318
|
Carver County Application |
| Dakota County |
Initial application: mail or email
hazardouswaste@co.dakota.mn.us
Dakota County Environmental Services
14955 Galaxie Avenue
Apple Valley, MN 55124
Renewals: Online using links sent via email
|
Dakota County Application |
| Hennepin County |
Hennepin County Hazardous Waste Licensing Portal |
|
| Ramsey County |
Initial application: Mail or email
ramseyHazWaste@ramseycounty.us
Ramsey County Environmental Health
1785 White Bear Avenue North, Suite 350
Maplewood, MN 55109
Renewals: Online using links sent via email
|
Ramsey County Application |
| Scott County |
Mail or email
Scott County Community Development Division
Environmental Health Department
200 Fourth Ave West
Shakopee MN 55379
hazardouswaste@co.scott.mn.us
|
Scott County Application |
| Washington County |
Mail or email
Washington County Public Health and Environment
14949 62nd St North
Stillwater, MN 55082
envhlth@co.washington.mn.us
|
To obtain an application, email PHE-HazWaste@co.washington.mn.us |
How to Submit an Annual Hazardous Waste Report in MPCA e-Services
Hazardous waste license applications can be submitted anytime between January 1st and August 15th (excluding Metro counties). Here are the key steps for using the Minnesota Online reporting system:
- Compile hazardous waste data including waste type, quantities generated, handling methods, shipments, and details about disposal facilities
- Go to MPCA e-Service webpage and either create a new account or sign in with your existing credentials.
- Click on the Hazardous Waste Generator License Application
- Type the 12 character EPA ID (referred to as HWID in the portal) of the site, click continue
- Review that the facility information is accurate, and select continue
- Report all Hazardous waste details from the previous year, including wastes shipped off-site or still accumulating at the end of the calendar year
- Types of waste generated
- Federal and MN waste codes
- Amount of waste generated and units of measurement
- Management methods
- Review for accuracy
- Sign electronically and submit your waste reports
- Confirm the application was submitted by navigating to My Services> Submitted
How to Submit a Hazardous Waste Report in RCRAInfo
LQGs in MN are required to submit federal biennial reports every 2 years. These reports are submitted through RCRAInfo and ensure compliance with federal RCRA regulations, during biennial reporting years. LQGs must submit a hazardous waste report through RCRAInfo by March 1st, and a hazardous waste license application to the state. Here are the key steps for using RCRAInfo to submit a biennial report for LQGs:
- Go to RCRAInfo and either create a new account or sign in with your existing credentials.
- Access the Biennial Reporting Module
- Compile hazardous waste data including waste type, quantities generated, handling methods, shipments, and details about disposal facilities
- Complete the necessary forms
- Site ID Form: provides contact information and a summary of waste activities for the previous year. This form is required for all facilities, regardless of generator status.
- Off-site identification form (OI) form: this form must be submitted for all off-site receiving facilities who:
- Shipped away waste that was on a UHWM to an off-site facility
- Generated special waste, regardless of generator status
- Had a planned or unplanned episodic event
- Generation and management (GM form) for each waste stream: describes waste streams generated and how the waste is managed.
- Provide federal waste codes, source codes, management methods, waste minimization codes, and waste quantities for each
- Review and submit your waste reports
- There are no federal fees associated with submitting biennial reports
Deadlines, Timelines RCRA Reporting Frequency
Annual Reporting Deadline
In MN, hazardous waste applications are due by August 15th for the Greater Minnesota area and have varying deadlines in the Twin Cities Metro area each year regarding information on hazardous wastes generated by the facility in the previous calendar year.
Additional Reporting Requirements (additional waste reports)
Episodic generation: As of 2025, MN has not adopted the federal generator improvements rule. This means that MN does NOT allow for episodic generation. Any events that cause a generator to increase their generation beyond the limits of their category must meet all of the requirements applicable to the larger category. The facility must then continue to follow all requirements of the larger facility each month for the rest of the year. Changes in generation status are not reported to MPCA, but on annual reports, but are updated on annual hazardous waste generator license applications.
Recycled Hazardous Waste Management Plan: Generators of hazardous waste that is recycled must submit a recycled hazardous waste management plan using forms provided by MPCA. One form is required for each waste stream that is recycled.
Tips for Effective RCRA Reporting
Maintain Continuous Records
- Implement a centralized storage system to ensure quick access to required documents and records. Documents and records may be requested during compliance audits and inspections and are helpful during the reporting system. Consider electronic storage or digital software for easier access and greater security.
- Conduct regular self-audits to ensure that records are accurate, complete, and compliant with current RCRA and Illinois regulations. Consider scheduling quarterly or biannual audits of generation, storage, and shipment records and keep track of deadlines for submissions
Understand State-Specific Reporting Requirements
Reporting requirements in MN vary from federal reporting requirements and vary from county to county. Failing to understand Minnesota and county-specific requirements can lead to non-compliance issues, especially in businesses operating facilities in multiple counties. Some key differences in reporting requirements in MN versus other states include:
- Annual reports in MN are known as hazardous waste license applications
- Metro counties have different deadlines and different application processes than the rest of the state
- Washington County has special waste codes for oil wastes
- MN has an additional category for non-RCRA hazardous waste: Lethality
- MN has a separate generator category known as MiniQGs which are exempt from reporting annually, but report every 3 years
- Deadlines for license applications range based on county
Keep Copies of All Submitted Reports
Make copies of all paper forms and securely store them for at least 3 years to stay compliant in MN. During compliance inspections, forms, waste determinations, training, records, and more may be requested.
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:
- Use standardized tracking systems
- Consider electronic tracking or digital software to calculate quantities based on generation and shipments automatically
- Conduct regular audits of waste totals
- Use accurate container labels
Failure to Report All Hazardous Wastes
Failing to report all hazardous wastes can occur for many 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 non-hazardous waste, or relies on outdated waste determination rules. Failing to report all waste can lead to underreporting, misrepresenting generator categories, and non-compliance issues.
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 specific to your county
Failing to Keep Up-To-Date with Changes in Regulations
Failing to keep up with regulatory changes can be due to several 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 MPCA and county environmental professionals
Tips:
- Assign a designated staff member or team to monitor current waste regulations
- Subscribe to updates from federal agencies and local EHS groups
- Implement software solutions to track hazardous waste regulations and notify of updates
Lack of Compliance with Minnesota-Specific Waste Regulations
Failing to understand the differences between federal RCRA requirements and specific rules can lead to non-compliance at the state level.
Tips to avoid non-compliance at the state level:
- Regularly review Minnesota and county-specific regulations by consulting the MPCA or environmental compliance experts in the state
- Train employees on Minnesota requirements
- Consider digital waste tracking and reporting software that supports state-specific monitoring
Late and Missed Submissions
Ineffective timeline management can lead to late and missed report submissions. Lacking a centralized compliance center, unclear designation of responsibilities, and insufficient training can contribute to missing deadlines.
Tips:
- Establish a centralized compliance calendar with reporting deadlines
- Use software to track and notify of reporting due dates
- Provide training to ensure employees understand when reports are due and the consequences of missing these deadlines
Penalties for Non-Compliance with RCRA Reporting in Minnesota
Potential Fines and Legal Consequences
In Minnesota, non-compliance with RCRA reporting requirements can lead to penalties, including fines and civil or criminal enforcement actions. Fines can be based on the severity and frequency of violations, knowledge of the violation, and other factors.
Common penalties include:
- Failing to submit annual or biennial reports: fines of up to $25,000 per day
- Late submissions of annual reports: 8% per annum calculated from March 1 and a penalty of 5% of total fees due for every 30-day period the report is late
- Exceeding storage limits: civil fines of up to $25,000 per day
- Failing to keep manifests up to date in e-Manifest system: Civil penalties of up to $25,000 per violation
