Missouri RCRA Hazardous Waste Reporting

In Missouri, hazardous waste reporting under the Resource Conservation and Recovery Act (RCRA) is a vital process to ensure that hazardous materials are properly tracked and managed from generation to final disposal. Hazardous waste at the state level is managed by the Missouri Department of Natural Resources (DNR). Staying compliant with Missouri’s hazardous waste reporting requirements is essential to protecting public health, maintaining the health of the environment, and avoiding costly penalties. Missouri reporting requirements can be more stringent than federal regulations, including state-specific reporting forms and increased frequency

Understanding Missouri Hazardous Waste/ RCRA Reporting Requirements

Who Needs to Report?

In MO, there are both quarterly and annual summary reports. The type of reports due are based on a facility’s generator status and filing method. All facilities that receive hazardous waste from an off-site generator, as well as all registered large and small quantity generators are required to report. MO follows federal thresholds for defining generator categories as:

• Small Quantity Generators (SQGs): generate between 220 and 2,200 lbs of hazardous waste and less than 2.2 lbs of acutely hazardous waste per month
  • Required to report annually 
• Large Quantity Generators (LQGs): generate more than 2,200 lbs of hazardous waste or more than 2.2 lbs of acutely hazardous waste per month 
  • Required to report quarterly if filing paper reports
  • Required to report annually if filing through the E-reporting system
  • Required to submit biennial reports through RCRAInfo every 2 years
• Treatment Facilities:
  • Report annually if filing through the E-reporting system
  • Report quarterly if filing paper reports
  • Required to submit biennial reports through RCRAInfo every 2 years

State-Listed Hazardous Waste in Missouri

Missouri does not have state-specific wastes or waste codes subject to RCRA reporting. Missouri has adopted all federal waste categories and codes defined by the EPA. 

A full list of all EPA waste codes is available here

Missouri Generator Statuses and Requirements

Very Small Quantity Generators (VSQG) Requirements

In MO, VSQGs are referred to as Conditionally Exempt Small Quantity Generators (CESQGs). CESQGs generate less than 220 lbs of hazardous waste and less than 2.2 lbs of acutely hazardous waste per month. CESQGs are generally exempt from reporting requirements but still have to take steps to ensure compliance with hazardous waste laws, including:

• Conduct hazardous waste determinations for all waste streams 
• May register with DNR, but are not required to
• Transport waste to a TSDF (do not need a manifest or a licensed transporter)
• Must report if the facility maintains an active EPA ID number

Small Quantity Generator (SQG) Requirements:

• Conduct hazardous waste determinations for all waste streams 
• Register with DNR by completing the Notification of Regulated Waste Activity Form 
  • Pay registration fee
  • MO will assign a federal EPA ID and a Missouri Generator ID number
• Operate the facility in a way that minimizes the possibility of an explosion, fire, or spill
• Have an emergency coordinator available at all times to respond to emergencies
• Attempt to make arrangements with local emergency agencies, including fire departments, police, and hospitals 
• Manage waste through on-site recycling or the use of a permitted TSDF. SQGs may use TSDFs in and out of state 
• Use the Uniform Hazardous Waste Manifest for all waste shipments
• Maintain records for at least 3 years
• Submit Generator’s Hazardous Waste Summary Report Form annually by August 14th 
• Submit a facility summary report each year by August 14th if the facility generates and manages hazardous waste on-site

Large Quantity Generator (LQG) Requirements:

• Conduct hazardous waste determinations for all waste streams 
• Register with DNR by completing the Notification of Regulated Waste Activity Form 
  • Pay registration fee
  • MO will assign a federal EPA ID and a Missouri Generator ID number
• Manage waste onsite properly, including:
  • Safe storage
  • Accurate labeling: include the words “hazardous waste” on waste containers 
  • Weekly inspections of hazardous waste storage areas 
  • Accident prevention 
  • Not allowing accumulation to occur for more than 90 days without a permit 
• Must have a formal contingency plan with a designated emergency coordinator. The plan must include contact information, procedures for spills or other emergencies, a list of emergency equipment with locations, and evacuation routes for your facility
  • Contingency plans must be on file with local emergency response agencies, including fire and police departments and hospitals 
• Conduct formal employee training for employees handling hazardous waste within 6 months of hire
• Only use a permitted TSDF or recycler 
• Use the Uniform Hazardous Waste Manifest (UHWM) system for waste shipments 
• Maintain records for a minimum of 3 years 
• Submit Generator’s Hazardous Waste Summary Report Form annually by August 14th 
  • If submitting via paper, submit summary reports quarterly by September 20, December 31, March 31, and June 30th
• Submit a facility summary report each year by August 14th if the facility generates and manages hazardous waste on-site
• Submit federal biennial reports to the EPA via RCRAInfo every 2 years by March 1st

Key Points:

Whenever there is a change in generator status (including episodic events), ownership, waste streams, or business name, generators must complete and submit a new Notice of Regulated Waste Activity Form.

Examples of Facilities Subject to Waste Reporting

The following is a list of facilities in MO and the wastes generated that would likely trigger the need to submit an annual or quarterly summary report:

• Chemical manufacturing plants: spent solvents, ignitable wastes, caustic liquids, tars, distillation bottoms 
• Metal fabrication and finishing facilities: chromium waste from electroplating, lead-contaminated waste, wastewater treatment sludge, silver-bearing waste
• Automotive repair shops: spent solvents, waste paint thinners, lead-acid batteries, waste from brake cleaners, waste pigment 
• Healthcare facilities: mercury-containing devices, acutely hazardous pharmaceuticals, ignitable lab solvents, formaldehyde, barium 
• Food and beverage manufacturing facilities: corrosive cleaning agents, spent solvents, chromium

Hazardous Waste Manifest Requirements for Missouri Facilities

Missouri has adopted all federal standards applicable to hazardous waste tracking, including the use of hazardous waste manifests. MO requires the use of the EPA Uniform Hazardous Waste Manifest for all shipments of hazardous waste by a Small or Large Quantity Generator. Waste manifests may be paper or electronic. Paper copies of manifests must be uploaded to the federal e-Manifest system. 

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 
• Signatures from generators, transporters, and final receiving facilities
• Emergency response numbers and emergency spill cleanup procedures 

For Generators:

• Missouri does not require manifest copies to be submitted to DNR
• MO 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 SQGs 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 DNR
    • 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 DNR within 15 days of accepting the waste. This report includes information about the facility, the waste type and quantity, the method of treatment, storage, and disposal, and an explanation of why the waste was unmanifested.  By December 1, 2025, unmanifested waste reports must be submitted into e-Manifest within 20 days of accepting the waste.
• 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 with DNR detailing the discrepancy, copies of waste manifests, and attempts to resolve the issue.  By December 1, 2025, discrepancy reports must be submitted into eManifest within 20 days of the incident

Common Manifest Errors

• Missing information: including EPA ID numbers, container counts, and state waste codes
• Inaccurate information: Transposed numbers, incorrect dates, incorrect units of measure for waste quantities 
• Mismatched or invalid Manifest Tracking Numbers (MTN)

Missouri Electronic Waste Reporting System (MoGEM)

Overview of MoGEM

Missouri utilizes the state-based Missouri Gateway for Environmental Management (MoGEM)  for annual reporting. Facilities in MO may submit annual reports via mail or electronically through MoGEM. If using electronic submission of reports through MoGEM, generators who are currently required to report on a quarterly basis will only be required to submit annually. MO encourages electronic reporting to support a unified and standardized platform.

How to Submit a Hazardous Waste Report in MoGEM

Here are the key steps for using MoGEM Online Reporting system to submit the Generator’s Hazardous Waste Summary Reports:

1. Go to the MoGEM homepage and log in using existing credentials or register for access
   • To register, you must identify a role as a viewer, preparer, certifier, or official
2. Compile hazardous waste data, including waste types, quantities generated, handling methods, shipments, and manifest copies
3. There are 2 parts to the annual report, each with several sections. Generators may fill out the forms electronically through MoGEM or upload an Excel file with the completed information. Below are the sections of the report to be completed for electronic reporting:
   1. Part I:
      • Section A: Report identification (EPA ID and MO ID)
      • Section B: Contact information
      • Section C: Status of waste generated
      • Section D: Comments
      • Section E: Certification Statement
   2. Part II:
      • Section F: Report Identification
      • Section G: Waste identification (descriptions, waste codes, quantities, tax codes, management methods)
      • Section I: Transportation services
      • Section J: Comments
4. Only certifiers or organizational officials may submit final reports 

Key Points:

• Facilities that need to submit via Excel will need to contact DNR via email to request the Excel templates
• Facilities that report quarterly are only required to submit once per year if they submit electronic reports
• Paper reports may be submitted via mail. These forms must have a wet ink signature, digital signatures are not accepted. Print and sign the completed forms and mail them to 

Missouri Department of Natural Resources

Waste Management Program

P.O. Box 176

Jefferson City, MO 65102-0176

Deadlines, Timelines RCRA Reporting Frequency

Annual Reporting Deadline

Annual reports are due August 14th, regarding information from the previous reporting year. Reporting years begin July 1 and end June 30 of the following year.

Additional Reporting Requirements (additional waste reports)

Facility Summary Report: Any large or small quantity generator that generates and manages hazardous waste on-site must also submit a facility summary report annually by August 14th. This report can be submitted electronically via MoGEM or paper. Any generator submitting paper summary reports must submit quarterly. Facility Summary Reports have 2 parts:

• Part 1: 
  • Section A: Report identification (EPD ID and MO ID)
  • Section B: Facility identification (address and contact information)
  • Section C: Activity Level
  • Section D: Comments
  • Section E: Certification (If submitting by mail, a wet signature is required)
• Part 2:
  • Section F: Report Identification
  • Section G: Generator Identification (Name, generator category, number of shipments received)
  • Section H: Waste identification (description, waste code, quantity, and management method code)
  • Section I: Comments

Federal biennial reports: LQGs are required to submit hazardous waste reports to the federal EPA every 2 years. These reports are due by March 1 and are completed through RCRAInfo

Episodic generation: If a facility experiences a one-time generation event causing them to exceed the limits of their generator status, the facility must update their generator status. The facility is required to follow all regulations for the new generator category, including submitting the Generator’s Hazardous Waste Summary Report. After the event, the facility may return to its original generator status by notifying the DNR. 

• Any facility experiencing an episodic event must submit an updated Notice of Regulated Waste Activity and a letter to DNR detailing the reason for the event, the amount of extra waste, the period of the event, and a request to return to their origin generator category following the event
• SQGs may have 1 episodic event in a 12-month period and may store the waste for no more than 30 days
• SQGs experiencing an episodic event in an odd-numbered year that causes them to reach LQG status must submit a federal biennial report

Tips for Effective RCRA Reporting

Maintain Continuous Records

• Continuously tracking waste generation data will help with making sure a facility is maintaining its generator status all year and assist in promptly identifying any changes
• Continuously and thoroughly recording waste can help ensure waste data is accurate and ready to go when the August 14th deadline comes around each year. A good rule of thumb is to have data ready to review the first week of July.
• 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 the facility maintains up-to-date records of all training sessions including dates, topics covered, attendees, etc. and store these records for 3 years to ensure compliance. 

Understand State-Specific Reporting Requirements

• MO requires all small and large quantity generators to submit both hazardous waste summary reports and facility reports annually 
  • There are two submission methods, paper submissions require quarterly reporting
• MO annual reports are due August 14th, which is different from federal reporting due dates
• LQGs in MO must also submit biennial reports through RCRAInfo every 2 years. MO annual reporting does NOT satisfy federal reporting requirements

Keep Copies of All Submitted Reports

Keep copies of all reports for a minimum of 3 years to stay in compliance in MO

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 overreporting 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

Omitting certain waste types can happen unintentionally due to a variety of factors such as a lack of understanding of MO regulations, incorrectly identifying wastes, failure to include nonhazardous industrial wastes, failure to assign correct waste codes, or failure to report wastes that are otherwise federally exempted.

Tips: 

• Conduct regular waste assessments to ensure proper classification
• Regularly update waste determinations
• Verify waste information with waste disposal facilities 
• Refer to MO guidelines for determining if waste needs to be included in annual reports

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 the state.

Tips: 

• Assign a designated staff member or team to monitor current waste regulations
• Implement software solutions to track hazardous waste regulations and notify of updates 
• Stay informed: subscribe to updates from MO to keep up to date on any deadlines 
• Join county and state EHS associations to stay up to date about regulatory changes

Lack of Compliance with Missouri-Specific Waste Regulations

The following may cause a facility or generator to be out of compliance in Missouri:

• Missing the August 14th deadline for annual report submissions
• Failing to complete both the Generator’s Hazardous Waste Summary Report and the Facility Summary Report 
• Not immediately notifying DNR of an episodic event   

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. Failing to submit generators;s hazardous waste summary reports and facility summary reports and other reports may result in fines of up to $10,000 per day. 

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 Missouri

Potential Fines and Legal Consequences

In Missouri, non-compliance with RCRA reporting requirements can lead to penalties, including 

fines and civil or criminal enforcement actions. These penalties and fines are enforced by the DNR and the federal EPA. MO also issues administrative orders and criminal charges to facilities and operators who violate RCRA. Fines can be based on the severity and frequency of violations, knowledge of the violation, and other factors. As of January 8th, 2025, the maximum penalty for a RCRA violation is $93,058 per violation per day. The EPA is likely to increase this maximum penalty each year. 

Common penalties include:

• Failing to submit annual or biennial reports
• 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
• Operating as a TSDF without a permit
• Exceeding storage limits 
• Failing to keep manifests up to date in e-Manifest system