Do you generate hazardous waste? If you are reading this post, then I am sure the answer is a resounding yes! Did you know that you need an EPA ID number for that? Again, I am sure the answer is also yes, but did you know there are different types of EPA ID#s, and are you sure you are using the correct one for the type of waste you are generating? I will outline what you need to know – even if you need to apply for one – and guide you through the process of understanding what EPA ID# would be best for you as a generator.
All persons who generate, transport, recycle, treat, store or dispose of hazardous waste are required to notify the California Department of Toxic Substances Control (DTSC) of their hazardous waste activities. In California, this includes state ID numbers for non-RCRA hazardous waste. So, which type of # should you apply for? Some generators believe it is based solely on the amount of waste generated – similar to being a Large Quantity Generator (LQG) or a Small Quantity Generator (SQG) – but this is not the case and where a lot of the confusion stems from.
Here is a breakdown and cheat sheet for you that includes how to obtain each!
EPA ID# Type
Forms to complete
|Federal EPA ID#||If you generate greater than 100kg of RCRA hazardous waste and/or one kg of acutely hazardous waste per calendar month.||EPA Form 8700-12, Notification of Regulated Waste Activity* – http://www.epa.gov/hwgenerators/instructions-and-form-hazardous-waste-generators-transporters-and-treatment-storage-and
|California EPA ID#||If you generate less that 100kg of a RCRA waste and/or less than one kg of an acutely hazardous waste per calendar month.||DTSC Form 1358 – http://www.dtsc.ca.gov/HazardousWaste/upload/GISS_FORM_1358.pdf – you can mail, email (firstname.lastname@example.org) or fax your form to the DTSC.||$0|
|Temporary EPA ID#||There are two categories of temporary ID numbers. These are provisional EPA ID numbers, and temporary State ID numbers. You would either apply for a CA or Federal # again depending upon the amount of RCRA waste generated (see above). These ID #s are valid for 90 days.||For CA: click on this link to start the process: https://dtsc-web01.dtsc.ca.gov/epaid/default.aspx
For a Federal #, the form is the same as a permanent EPA ID# (EPA Form 8700-12). Original signatures are required (photocopies are not accepted). Mail the form to: California Department of Toxic Substances Control, Attn: RCRA Notifications, PO Box 806, Sacramento, CA 95812-0806
* This is a simple five-page form with 45 pages of explanation on how to fill it out! Unfortunately, it may be just the beginning of your journey understanding the question “What is with all this paperwork?!?”
If you have more questions (come on, you know you do), then keep on reading!
What is meant by RCRA waste?
Great question, but not an easy one! The California DTSC has put together a great information sheet for what defines a material as either a RCRA or Non-RCRA (California only) hazardous waste:
For more information or training on definition and classification of hazardous waste, please contact our consulting group to help you though this process!
Is an EPA ID# Site Specific?
If you answered ‘yes’ you are partially correct. EPA ID numbers are site specific except when they are issued to transporters. For generators they are site specific!
What if I move? Can I take my ID# with me?
No! EPA ID numbers are so important, because they help the DTSC/EPA track wastes through the entire cradle-to-grave cycle (the point of generation to the point of disposal). They DO NOT MOVE with the generator.
If you, as a generator, relocate your operations, you would want to inactivate your old EPA ID# once all of the waste is disposed of. You should even apply for your new ID# before operations commence so you can stay one step ahead, because as you now know, there is MORE paperwork ahead! Side note: the EPA does note that, “If, at the new location, a RCRA hazardous waste ID number had previously been issued to the former owner/operator, the number for that physical location will then be assigned to the new requester.”
Trudging your way through government information can be daunting…who wants to read a 50-page document! The forms alone are enough to make you wish it were Friday. Using ACT’s consulting department to help you understand the numerous requirements may be the simplest, most cost-effective use of your time and money. The most important thing is to get it right the first time, so that there are no repercussions to your business later.
– Krista Wood Harsono, Director of Compliance