Frequent Questions

Do I need two ID numbers if I have two companies both at the same site? The site itself has a generator ID number, but the waste process for each of the companies is different. Does that require two different numbers or just one because it is only one sit

A generator must not treat, store, dispose of, transport, or offer for transportation, hazardous waste without having received an EPA identification (ID) number from the Administrator.

The term generator is keyed to both person and site.  Generator means any person, by site, whose act or process produces hazardous waste identified or whose act first causes a hazardous waste to become subject to regulation.

Person means an individual, trust, firm, joint stock company, federal agency, corporation, partnership, association, state, municipality, commission, political subdivision of a state or any interstate body.

The two distinct companies (i.e. persons) must each apply for a separate EPA ID number.  Even though ID numbers usually are site-specific, where different people conduct different regulated activities on a site, a person conducting each regulated activity must obtain an EPA ID number.

References:  40 CFR Section 262.12
40 CFR Section 260.10
Monthly Call Center Report Question, February 1988 (RCRA Online #13129)

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