Notify EPA and obtain an EPA Identification Number

• EPA ID Numbers are 12-character identification numbers used by both EPA and the states as part of a national database to track hazardous waste activities.
• EPA ID Numbers are site-specific.
• A provision in the Hazardous Waste Generator Improvements Rule requires SQGs to re-notify EPA or their state every four years.

Once a facility knows the hazardous waste generator category, the facility must notify the Environmental Protection Agency (EPA) and/or the state of waste activities and obtain the EPA Identification (ID) Number.

Note: This step is not required for very small quantity generators (VSQGs) on the federal level but be sure to check with the state. Some states require VSQGs to obtain EPA ID Numbers.

EPA ID Numbers are 12-character identification numbers used by both EPA and the states as part of a national database to track hazardous waste activities.

The application for the number notifies the state and federal government that the company is involved in hazardous waste activity. The ID number that the company receives is used on all documents relating to hazardous waste: manifests, biennial reports, labels, etc.

To get the EPA ID Number, a company should call or write the state hazardous waste management agency or the EPA regional office and ask for a copy of EPA Form 8700-12, “Notification of Hazardous Waste Activity.” The form and instructions can also be found here: EPA website. A few states use a different form for notification, which can be found on the state’s waste agency website.

A company must resubmit the form any time the facility changes generator categories, activities, business ownership, or contact person. The agency uses site information to identify hazardous waste generators, handlers, and managers and their specific regulated waste activities. Of course, EPA and the states also use the information for inspection and enforcement purposes. And the information is made public through various databases.

EPA ID Numbers are site-specific. The regulations do not define the term “site,” but say that “activities occurring under the control of an owner or operator on a single piece of property should be evaluated collectively for hazardous waste generation.” If a company has several plant sites or business locations where the company produces or handles hazardous wastes, they will need to complete one copy of the form for each site. Each site will receive its own EPA ID Number.

The EPA ID Number stays with the business site or location that the company registered. If the business moves to another location, notify EPA or the state and submit a new form. If the new location previously handled hazardous waste, and already had an ID number, the company will be assigned that number for the site after notifying EPA.

Applying for an ID Number electronically: EPA has electronic reporting options available for the 8700-12/Site ID form in states that have opted in to using the electronic system. Check with the state environmental agency to see if this option is available.

SQGs re-notify EPA

A provision in the Hazardous Waste Generator Improvements Rule requires small quantity generators (SQGs) to re-notify EPA or their state every four years, beginning in 2021, about their waste activities. This is so states have a better handle on the number of SQGs in operation and the types of wastes they are generating. Use the same form (EPA Form 8700-12) to re-notify.

Transporters

Hazardous waste transporters are also required to obtain EPA ID Numbers, but they may submit one form that covers all of the activities for their entire company — unless they also treating or recycling waste. Generators may only use transporters that have EPA ID Numbers to ship their waste offsite.