Did you know, our Technical Team routinely monitors the status of your EPA ID number to ensure that you are not unknowingly transporting hazardous waste on an inactive EPA ID number? This is just one of the ways that we support your compliance obligations.
How Could This Happen?
To maintain an active EPA ID number, generators are required to complete an annual EPA ID Verification Questionnaire with the Department of Toxic Substances Control (DTSC). The purpose of this verification is to ensure that the information on record for the EPA ID Number is correct and current. This process used to be via paper notification and form. However, several years ago the process was changed to an entirely online system called eVQ. The system is far from perfect in that notifications only go to the email user they had on file for previous submissions. So, if your ID number is new or you have had personnel changes et., that notification could have been lost. If a 2017 Verification Questionnaire was not completed for your site using eVQ, your ID number was inactivated as of January 1. 2018. The DTSC does not send a letter informing you that your number was inactivated. It is very easy for this to slip through the cracks, which is why we routinely monitor it for you. You can read more here about the eVQ program including some helpful frequently asked questions.
If you are scheduling a waste pickup, your customer service representative will contact you if your EPA ID number is returning inactive.
What Do I Do?
If your EPA ID has been inactivated, you must complete one of two forms to reactivate it. Which form will depend on what type of EPA ID number you have. If yours is a state ID number (those beginning with the prefix CAL) you will need to complete DTSC form 1358. If your EPA ID number is a Federal number (beginning with prefix CAR, CA, CAD, or CAT), you will need to complete form 8700-12. Federal numbers can be updated using MyRCRAid, an online version of the 8700-12 form. Doing so through this online system will cut the processing time in half. While the form must be completed by someone at your facility, we are here if you have any questions or need any assistance. Please contact your Customer Service Representative.
If your number has been deactivated, it is very important that you immediately take steps to reactive it. According to the DTSC, “Any generator, transporter, or facility operator who fails to provide information required by the department to verify the accuracy of hazardous waste activity data shall be subject to suspension of any and all identification numbers assigned and to any other enforcement action (Health & Safety Code section 25205.16(c)).”
Our Commitment To Service
HTS Environmental Services is here to help, with this or any other compliance issues. Please don’t hesitate to contact your Customer Service Representative or anyone at HTS at (562) 906-2633.