**Q. T he one thing that was fuzzy was exactly what the administrative controls are for RCRA in the first place.
A. I should have differentiated Administration under RCRA, where I mean the paperwork, from ”administrative Controls,” a general concept in industrial hygiene that means separating workers from the hazard.

*Q. The RCRA discussion was very informative and simplified. I followed the large quantity generator and small generator explanation up to a point. You are a LQG if you generate >1000 Kg of non-acute waste in a month. You are a SQG if you produce between 100 Kg and 1000 Kg of non-acute waste. My question is lets say you accumulate 500 Kg of waste per month at the site. Your record keeping & labeling marks each storage container for each month separately, but then you ship them all on one manifest in 90 or 180 days. Are you still a SQG. What record keeping needs to happen to prove that these are separate but combined shipments?
A. If you label the storage containers, which probably become the shipping containers, you have a record of when each was produced. So, you stay a SQG, even though you ship more than 1000kg. I would check with the regulator to find out if I need to seal the drum on the 30 th day and start a new drum, or can I have a drum with some from this month and some from the next month. I won't split those hairs in this course, but those kinds of issues are common enough so the right person at EPA can give you a definite answer.