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Do you Need an EPA ID Number?

Do you Need an EPA ID Number?

An EPA ID number is a 12-character number assigned to each handler of hazardous waste. After the unique ID is assigned, the ID’s are used on hazardous waste manifests and other documents relating to the handler. This number is either given by the U. S. Environmental Protection Agency (U.S. EPA ID Number) or by the DTSC (California ID Number). This ID number allows regulators to track the generator’s waste from its origin to its final disposal, monitoring the waste from “cradle-to-grave.”

With the limited exceptions discussed below, an unique ID Number is required for most hazardous waste generators to have so a registered transporter could accept the waste for transportation. An ID number is also required for all transporters of hazardous waste and permitted treatment sites, as well as storage and disposal facilities (TSDFs).

State and Federal Laws

The federal hazardous waste law, known as the Resource Conservation and Recovery Act (RCRA), gives states the ability to enact their own hazardous waste laws. However, state laws must be as stringent as federal laws. (In California, the requirements under the state’s law are more stringent than the federal laws.) Wastes that do not meet any of the criteria of RCRA waste but match the California criteria are referred to as “non-RCRA” hazardous wastes. Because of this, other states may not consider California non-RCRA wastes hazardous. Small quantity hazardous waste generators are exempted by federal law from many federal waste management requirements.

Do You Need an EPA ID Number or a California ID Number?

ID Numbers are specific to one site, and a business will typically have one ID number at its address. If your business generates waste at more than one address and they are not connected physically, then each address must have a separate ID Number.

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If your facility generates over 1 kilogram of RCRA acutely hazardous waste each month, or more than 100 kilograms of other RCRA waste per month, you are required to obtain a U.S. EPA ID Number. Acutely and extremely hazardous wastes are wastes that may cause death, disabling injury, or serious illness. However, if you produce 100 kilograms or less of RCRA waste, or 1 kilogram or less each month of acutely hazardous waste and meet certain other requirements, you may be exempt from many EPA regulations, including the requirement for an ID Number.

California regulations do not have the same exemptions for small quantity generators. Nearly all California waste generators that are not required to have a U.S. EPA Number must obtain a California ID Number outside of the few exemptions listed in California Health and Safety Code. Outside of these exemptions, if you generate only non-RCRA hazardous wastes, or less than 100 kilograms of RCRA hazardous waste per month (or less than 1 kg. of RCRA acutely hazardous waste), you must obtain a California ID Number. If you generate over 100 kilograms of RCRA waste per month or over 1 kilogram of RCRA acutely hazardous waste per month, then you are required to get a U.S. EPA ID Number.

How do I Apply for an EPA ID Number?

RCRA waste handlers can acquire an EPA ID Number by sending a “Notification of Regulated Waste Activity” form to the U.S. EPA contractor at the address listed in its instructions. This form can be requested by calling (415) 495-8895, or can be downloaded from the U.S. EPA website. Handlers who are not required to apply for an EPA Number but are required to have a California ID Number can obtain it by completing and submitting the California Hazardous Waste Permanent ID Number Application.

If you have any questions or require assistance with this matter, please contact us.

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