As pressure grows on companies to improve sustainability performance, few compliance tasks are as quietly impactful as hazardous waste biennial reporting. These reports help regulators and businesses understand how hazardous waste is generated, managed, and ultimately treated or disposed of.
For organizations that handle significant volumes of hazardous waste, biennial reporting supports both compliance and broader sustainability goals.
What is Hazardous Waste Biennial Reporting?
The Biennial Report refers to the submission of detailed hazardous waste management data once every two years. The Biennial Hazardous Waste Report (EPA Form 8700-13A/B) is mandated under the Resource Conservation and Recovery Act (RCRA), 40 CFR 262.41.
The reporting requirement is applicable to Large Quantity Generators (LQGs) and facilities that receive hazardous waste from off-site and manage it on-site, including some Treatment, Storage, and Disposal Facilities (TSDFs). It covers the previous odd-numbered calendar year and is due by March 1 of the following even-numbered year.
For the current cycle, submissions open January 2, 2025, and are due March 1, 2026, with state agencies finalizing data later that year. Data is submitted via the EPA’s RCRAInfo Industry Application, and states may have additional requirements, such as an additional state notification form and/or an annual reporting requirement.
Who Needs to Report and When
Biennial waste reporting obligations vary by jurisdiction, but at the federal level, the Biennial Hazardous Waste Report applies to:
- Large Quantity Generators (LQGs) of hazardous waste (those meeting federal LQG thresholds in any calendar month)
- Facilities that receive hazardous waste from off-site and manage it on-site (submit a WR form as part of the report)
- Certain reverse distributors that manage evaluated hazardous waste pharmaceuticals
Small Quantity Generators (SQGs) and Very Small Quantity Generators (VSQGs) are not required under federal rules to file the Biennial Report, though states may impose additional or more frequent reporting obligations.
Reporting Frequency and Timing
- Due date: March 1 of every even-numbered year
- Covers: Hazardous waste activity from the previous odd-numbered year
- Platform: The EPA RCRAInfo Industry Application, unless a state mandates a different submission method or supplemental reporting
- Current cycle: Submissions open January 2, 2025, and are due March 1, 2026, with states finalizing data later that year
Some states have additional reporting obligations beyond the federal RCRA Biennial Report, such as annual waste reporting. Certain states also require separate annual reporting for Episodic Events or Hazardous Secondary Materials (HSM) to maintain specific exemptions or generator status. Because requirements vary, it’s important to confirm current expectations with your state environmental agency to ensure full compliance.
What Gets Reported
While states may require additional reporting, the Biennial Report generally includes:
- Site ID form: Facility information, current generator status, EPA ID number, and other site details
- GM (Generation & Management) form: Waste types and classifications (by EPA waste codes), quantities generated, on-site management methods, and off-site shipments (including the EPA ID of each receiving facility and management methods)
- WR (Waste Received) form: If the site receives hazardous waste from off-site, quantities received and how they were managed
- OI (Off-site Identification) form: Only if your state requires it; includes transporter and off-site installation details
The federal forms do not require detailed movement dates, transporter names, or incident/deviation reporting beyond what may be included in a general Comments field.
EPA’s current instructions emphasize that waste activity should be reported using federal regulatory definitions and generator categories unless a state specifically requests additional or alternative data.
Why it Matters: Beyond Compliance
While the Biennial Report is primarily a legal requirement, it also supports broader sustainability and operational goals. Accurate reporting helps organizations identify inefficiencies, reduce environmental risks, and contribute to public data that informs waste-management policy.
Challenges and Support Options for Hazardous Waste Reporting
Hazardous waste reporting often presents more complexity than expected. Organizations may struggle with inconsistent data across sites, unclear waste classifications, or evolving state and federal requirements. In some cases, reporting processes rely heavily on manual inputs or legacy systems that aren’t designed to handle current compliance expectations.
These issues can be addressed through advanced data management, staff training, and clearer internal workflows. But for many teams, especially those managing multiple facilities or large waste streams, outside support can help ensure accuracy and efficiency.
Tetra Tech provides technical and regulatory support to organizations navigating waste reporting. Our team includes subject-matter experts in hazardous-waste management and environmental compliance who work alongside clients to improve reporting systems and meet requirements with confidence. If your company needs support, reach out to our team at [email protected] today.
