How to Get an EPA ID Number to Generate Hazardous Waste

Posted on 7/13/2020 by Robert Clarke, CDGP and Scott Dunsmore, CIT

The Resource Conservation and Recovery Act (RCRA) hazardous waste regulations require any person who generates, transports, or recycles hazardous waste—or who owns a hazardous waste treatment, storage, or disposal facility—to notify EPA of their activities and obtain an EPA ID number [RCRA §3010].

Assigning a unique EPA ID number to each generator, transporter, and TSDF enables US EPA and state agencies to identify all the players within the hazardous waste management program.

This sounds simple enough. If you work with hazardous waste, you don’t want to keep it a secret. But how do sites register their activities with EPA? How do you get an EPA ID number?

This blog answers three common questions from hazardous waste generators concerning EPA notification and EPA ID numbers:
  • Do we need an EPA ID number?
  • How do we get an EPA ID number?
  • When and how do I notify and re-notify EPA of my activities?
In addition, we will discuss how a new requirement for re-notification recently added in US EPA’s Hazardous Waste Generator Improvements Rule may impact your site.  

Need annual RCRA training? Join an expert Lion instructor for the one-day RCRA Refresher webinar on August 4 or August 18. 

Do I Need an EPA ID Number?

You must register for an EPA ID number if your site meets the definition of a:
  • Small Quantity Generator (SQG) as defined at 40 CFR 260.10;
  • Large Quantity Generator (LQG) as defined at 40 CFR 260.10; or
  • Large Quantity Handler (LQH) of universal waste as defined at 40 CFR 273.9.
Very Small Quantity Generators or VSQGs—formerly known as Conditionally Exempt Small Quantity Generators or CESQGs—do not need to register as generators of hazardous waste. For a definition of VSQG, see 40 CFR 260.10.

How Do I Register with EPA as a Generator?

To notify EPA of your activities and obtain an EPA ID number, you must submit a standard Site Identification form (EPA Form 8700-12) to your state environmental agency. If your state does not have a hazardous waste program you register with the EPA regional office that serves your state.

Note: Some authorized states may have their own notification form. These state forms may include additional information that the state requires from the generator. The generator will need to review their state’s regulations to determine whether to use Form 8700-12 or a state-specific form.

Lion Members can view all 50 state’s unique hazardous waste requirements anytime in the Member Area.

For large and small quantity hazardous waste generators, general information provided on Form 8700-12 includes:
  • The facilities name and address
  • A description of the site
  • The sites North American Industry Classification System (NAICS) code(s)
  • Sites contact information
  • A description of the hazardous waste activities conducted at the site including but not limited to the types of hazardous waste generated, expected waste codes, what types of recycling activities, and expected ultimate disposal activities such as burning or treatment and landfilling.
For more information on how to submit Form 8700-12, see EPA's detailed instructions here. 

Learn more about the hazardous waste site ID/notification process here. 

Electronic EPA ID Form Submission

While Form 8700-12 is available to be prepared and submitted in paper form, the EPA encourages individuals to submit their notifications electronically.

The Agency has an electronic reporting tool known as the RCRAInfo Industry Application (RIA). Through RIA, generators can submit notifications using myRCRAid reporting application. Currently, eighteen (18) of the fifty (50) states allow or require electronic submission. Of those, many use the RCRAInfo online portal for preparation and submission.

As noted above, some states have their own versions of the notification of activity notification forms. States with their own forms may require paper submission, or electronic submission through another application.

To see what your state may require, you can refer to the EPA’s website.

When Do I Update My Registration?

Generally, if any the following things change you must update your registration:
  • A change of site contact
  • A change or addition of ownership
  • The type of hazardous waste activity changes
  • Opting in or out of managing laboratory waste under 40 CFR Part 262, Subpart K
Note: Updating your EPA registration is not required when you generate a "new" waste not covered on your initial notification. You will let EPA know about the new waste when you re-notify. 

Do I Have to Re-notify EPA?

The hazardous waste Generator Improvements Rule (84 FR 85732, November 28, 2016) requires both large and small quantity generators to periodically renotify the Agency of their generation activity.

If your state has adopted the RCRA changes in EPA's generator improvements, your timeline for re-notifying EPA depends on your generator status.
  • If you are a Small Quantity Generator, beginning in 2021, you must re-notify by September 1st using the EPA Form 8700-12 and re-notify again every 4 years afterwards. (40 CFR 262.18(d)(1)).
  • If you are a Large Quantity Generator, re-notification is required by March 1 of each even-numbered year. You may submit your re-notification to EPA when you submit your Biennial report by March 1st of each even numbered year (40 CFR 262.18(d)(2)).

Other Uses for Form 8700-12

Form 8700-12 has undergone numerous revisions over the forty-year history of the hazardous waste regulations. Currently, in addition to the general notification of hazardous waste activity, the form is used for various additional notification reporting requirements, including:
  • Used oil activity reporting
  • Hazardous secondary material reclamation activity
  • Episodic generation
  • LQG consolidation of VSQG waste activity
  • Hazardous waste pharmaceutical activity
  • Academic laboratories operating under the provisions of 40 CFR 262, Subpart K
  • Large quantity generator closure (i.e., central accumulation area or entire facility)
  • Electronic manifest system broker notification

Summer 2020 RCRA Refresher Training

online RCRA hazardous waste trainingGet your annually required RCRA training and keep your expertise up to date! Join a Lion instructor for the RCRA Hazardous Waste Management Refresher Webinar on July 28, August 4, or August 18.

Or train at your own pace with the initial or refresher RCRA online courses. 
RCRA Hazardous Waste Management Online Course
RCRA Hazardous Waste Management Refresher Online Course

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