Does My Facility Need an EPA ID Number?
July 10, 2023
Does My Facility Need an EPA ID#?

It can become problematic when a facility is suspicious of EPA ID numbers or if you do not understand what they are. These ID numbers are not nonessential, and if your facility is required to have them, it is the law that you do. Failure to have an EPA ID number when it is required puts your facility at risk for civil and criminal penalties.

The purpose behind an EPA ID number is to make sure all hazardous materials can be tracked and monitored from ‘cradle-to-grave’. ‘Cradle-to-grave’ means from the point the hazardous waste is created to its final disposal point. As a generator, your facility is responsible for your hazardous material even when it is no longer on your facility’s property. The EPA ID numbers listed on the paper trail are what make your facility accountable for proper handling all the way through to the disposal of the waste.

Who Needs an EPA ID Number?

If your facility generates or transports hazardous materials, or if your facility is responsible for recycling, disposing, or treating hazardous waste materials, you must disclose your activities to the regional EPA office, or an authorized state waste management office. If your facility generates more than 220 lbs of hazardous materials in a month, you need an EPA ID#.

Knowing whether or not your facility is required to have an EPA ID# is not always easy to determine. Working with a reputable and experienced hazardous waste management service, such as Environmental Marketing Services, will help you understand this process. The professionals at EMS will ensure your facility follows all the confusing and complicated laws surrounding hazardous waste disposal.

If it is determined your facility requires an EPA ID#, a completed Form 8700-12, Notification of Regulated Waste Activity has to be filed with your regional office where your facility operates or the EPA office. On Form 8700-12, you will need to include:
– Your facility’s complete name and address
– Complete contact information for your facility
– Full description of the hazardous waste activities performed on your site

A significant factor in determining whether or not your facility is required to have an EPA ID# is what type of hazardous waste you generate. The ID#s are divided into two categories.

State EPA
– Your state laws vary from other states. To learn what your specific state laws require, talk to the professionals at Environmental Marketing Services.
Federal EPA
– If your facility handles RCRA hazardous waste materials, you will be required to obtain a Federal EPA ID#. If you are generating more than one hundred kilograms of these waste materials, and more than one kilogram of RCRA acute hazardous waste material in a month, an EPA ID# is required.

If you are unsure as to whether or not your facility falls within these guidelines, talk to the experts at EMS.

What is Considered Hazardous Waste?

Waste material is identified as hazardous if it has a chemical composition or other properties that make it capable of causing severe illness or death to humans or other life forms when it is released into your environment.
The EPA (Environmental Protection Agency) is a regulatory program created by the federal government and is designed to ensure dangerous waste materials are handled properly. This program has created a precise outline of hazardous waste and directions on how they are to be handled. If you are unsure how your waste should be handled or classified, talk to the experts at Environmental Marketing Services.

Exemptions to EPA ID Numbers

The EPA ID number assigned to your facility will identify the type of waste you generate and handle. This number will be placed on your waste manifest and all other paperwork regarding your waste materials. This ID number will also allow regulators to monitor and track your waste from the time you generate it through to its final disposal site.

There are some exemptions to having to have an EPA ID number, however, most hazardous waste generators will be required to obtain one. Without the number, a transport service of waste materials will not be allowed to accept your waste for shipment. The ID number will also be required for permitted treatment, storage, and disposal facilities.

Some of the exemptions for being required to have an EPA ID number include small quantity generators. If your facility is considered a small quantity generator, you may only be required to file state-specific reports to your state. Talk to Environmental Marketing Services to learn if your facility is required to have the EPA ID#.
There are three questions to answer if you are trying to determine whether or not your facility is required to have an EPA ID number:

– Since one of the factors determining the need for the ID number depends on how much hazardous waste you generate, you need to ask what your State’s requirement is in regard to the volume of waste.
– Are your waste materials classified as ‘hazardous?’
– How much material will you need to be shipped for storage, treatment, or disposal?

The law states that if a facility generates less than 2,200 pounds of waste in a month, they are considered a ‘small-quantity’ generator. If you generate more than 2,200 pounds of hazardous materials, you are then considered a ‘large-quantity’ generator.

Large-quantity generators are required to have the EPA ID# regardless of which state they operate in. If you are a small-quantity generator, talk to Environmental Marketing Services to learn if you fall under an exemption rule.

Understanding Your EPA ID Number

There are several factors to understand regarding your EPA ID number.

1. The EPA ID number is required for your facility to ship hazardous materials. It is against federal laws for you to ship hazardous materials without this ID number if your facility requires an EPA ID.
2. Large-quantity generators must ship their hazardous materials within ninety days and pay a tax on the tonnage of these materials.
3. The EPA ID number assigned to your facility is site-specific. Should your facility move, you will be required to file for a new number.
4. If you are a transporter of hazardous materials, it would be illegal for you to accept any materials from a company or customer without an EPA ID number. There are built-in checks and balances in this system, so facilities cannot operate without the proper filing of EPA ID numbers.

Does Your Facility Need More Than One EPA ID Number?

Facilities of hazardous materials are required to have a separate ID number for:
– State EPA ID- the state EPA ID number is owner and site-specific
– Federal EPA ID- the Federal EPA ID number is site-specific

If your facility consists of different locations which are not physically connected, you will be required to have an EPA ID number for each separate location. If your facility has a shared location with other businesses and each of you generates hazardous materials, each of you will be required to file for separate EPA ID numbers. Any questions regarding the necessity for an EPA ID number can be directed to Environmental Marketing Services.

Local Hazardous Waste Disposal Service

Environmental Marketing Services is a team of professionals who welcome the opportunity to help you understand and manage your hazardous materials. We have more than ninety years of combined experience in the industry and understand the need to develop cost-effective and innovative solutions to manage your recycling and disposal needs. Contact our office if you have any questions on EPA ID numbers or other disposal or recycling management.

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