Does My Facility Need an EPA ID#?
January 6, 2021

An EPA Identification (EPA ID#) number is required for small and large quantities of hazardous waste generators. This requirement is from the Federal government, and to obtain one; you would use Form 8700-12 from the EPA (Environmental Protection Agency.)

The completed Form 8700-12 must be submitted to your regional office of the EPA or an authorized state agency if the State you are operating in does not implement the RCRA (Resource Conservation and Recovery Act) Subtitle C program. On the form 8700-12, site identification form, you will need to include:

– The name of your facility and complete address
– Your contact information
– A full description of the hazardous waste activities conducted on your site

What is Considered a Hazardous Waste?

The most basic answer to ‘what is considered a hazardous waste’ there is a simple answer. A waste material identified as ‘hazardous’ is one with chemical composition and or other properties, making it capable of causing severe illness or death to humans and other life forms when the material is released or mismanaged into your environment.

A regulatory program was created by the Environmental Protection Agency (EPA) to make sure there is safe handling of these dangerous waste materials. This program makes it necessary to follow precise definitions of ‘hazardous waste.’ Because of this necessity, the EPA has an outline to follow in determining which materials are considered ‘hazardous’ for the purposes of RCRA. Check with your local waste disposal service, Environmental Marketing Service, if you are unsure how your waste should be classified.

How to Know if Your Facility Needs an EPA ID#

The hazardous waste management industry is highly regulated and controlled through both federal and state laws. These strict laws can determine how to safely and legally deal with your hazardous waste, a confusing and complex process.

When you work with an experienced and knowledgeable hazardous waste management service, such as Environmental Marketing Services, the process can go much smoother. Having a professional service working with you will also ensure you follow all the complicated and confusing laws surrounding hazardous waste disposal. One of the most asked questions is, ‘how do I know if my facility needs an EPA ID#?’ Knowing whether or not your facility needs an EPA ID# is not always a straightforward answer. Federal regulations dictate if you need this ID#, but it mostly depends on your State.

One of the significant factors determining whether or not you will need the ID# is the type of hazardous waste your facility generates. The numbers are divided into two categories:

State EPA-
These hazardous wastes are determined under your state laws, which vary from state to state. A professional hazardous waste service such as Environmental Marketing Services can advise on each specific state regulations.
Federal EPA ID-
Federal EPA ID#s are issued if you handle RCRA hazardous waste materials. If your facility generates more than one-hundred kilograms of these wastes, and more than one kilogram of RCRA acute hazardous wastes a month, it will be necessary for your facility to have a federal EPA ID#.

Your EPA ID number will identify what type of hazardous waste you handle. This information will be on your waste manifest and other paperwork. The number will also allow regulators to track your waste from where it is generated to its final disposal site. This process is known as the ‘cradle to grave.’

There are a few exemptions to needing an EPA ID number, but typically most hazardous waste generators are required to have an EPA ID number, or a transporter of waste cannot accept the waste for shipment. EPA ID numbers are also required for permitted treatment, disposal, and storage facilities.

There are some exemptions to needing an EPA ID number for small quantity generators. As a small quantity generator, however, you may be required to file state-specific reports for the state where your facility is located. To determine your hazardous waste requirements, check with your local waste disposal service, such as Environmental Marketing Services.
An additional factor that determines whether or not your facility needs an EPA ID number is the amount of hazardous waste you generate.

There are three questions to answer when trying to decide whether you need the ID number:
What is your State’s requirement in regards to the volume of waste?
Is the waste you’ve generated been identified as ‘hazardous?’
How much of the waste needs to be shipped?

Do Small Quantities of Hazardous Waste Require EPA ID Number?

Under the law, if your facility generates less than 2,200 pounds of waste, you are considered a ‘small quantity generator.’ If your facility generates more than 2,200 pounds of hazardous waste, you are considered a ‘large quantity generator.’ As a ‘small quantity generator,’ your facility is required to obtain an EPA ID number, regardless of the State where you operate. ‘Large quantity generators’ are also required to have the number to ship their waste.

What You Should Know About Your EPA ID Number

When having an EPA ID number, several points need to be kept in mind:
The EPA ID number is required for you to ship any hazardous waste. It is against federal regulations to ship any hazardous materials without the ID number required for your facility.
It is required under the law for you to report your waste generator status to the federal government.
Large quantity generators are required to ship hazardous waste within ninety days. It is also required that you pay a tax on the tonnage.
The numbers assigned to EPA ID numbers are site-specific. If you move your facility, you will be required to apply for a new number.
If you know of a facility that has not filed for an EPA ID number, it would be illegal for you to accept their hazardous waste. This law is a built-in check and balance system, so facilities cannot operate without proper filing for needed ID numbers.

Emergency Hazardous Waste EPA ID Numbers

Some situations can occur that require emergency hazardous waste EPA ID numbers. Some of these situations include spills or clandestine lab cleanups. These emergency ID numbers are generally only issued to government agencies or their contractors.

There are two categories for emergency EPA ID numbers:
Federal Emergency EPA ID numbers are issued for 100 kilograms or more of RCRA hazardous waste, or 1 kilogram of more acute hazardous waste
State Emergency EPA ID numbers are issued for all other hazardous waste

Does My Facility Need More Than One EPA ID Number?

Every facility that generates hazardous waste is required to have a separate ID number:
State EPA ID numbers are owner and site-specific
Federal EPA ID numbers are site-specific

If your facility generates waste at different locations that are not physically connected, each of those locations will need a separate EPA ID number. If your business is in a shared location with other businesses where all of you generate hazardous waste, each of you is required to have separate EPA ID numbers. If you are unsure whether or not your business needs a number, check with a professional waste disposal service to learn if you need to file for the number.

Your Local Hazardous Waste Disposal Service

Environmental Marketing Services provide manufacturing facilities, educational systems, and more with waste disposal services. We have more than ninety years of experience in the industry and welcome your questions on how to be of service to your facility. Through our services, you are ensured that your waste disposal will be handled most cost-effectively and innovatively to reduce your liability and protect your environment.

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