Frequent Questions

A generator has multiple structures within the same contiguous property. Is each structure required to have an individual EPA identification number?

For the purposes of generator notification and obtaining EPA identification numbers, and assuming the structures are on-site as defined in §260.10, one identification number is sufficient for all structures at the facility site (Memo, Shapiro to Wojdyla; May 1, 1996 (RCRA Online #14031)). EPA identification numbers are issued to facilities on a by-site basis (Memo, Barnes to Bider; August 15, 1989 (RCRA Online #11456)). There is no regulatory definition for the term “by-site”; however, it refers to where a hazardous waste is generated (Memo, Shapiro to Wojdyla; May 1, 1996 (RCRA Online #14031)). 

For example, if a single company operates three laboratories on a single piece of property, all three laboratories may share one EPA ID number, and the waste from all three laboratories may be evaluated together. However, if the company operates three laboratories at three different locations that are not considered to be on contiguous property, each laboratory is viewed as a separate potential generator and is required to obtain an individual EPA ID number (Memo, Shapiro to Wojdyla; May 1, 1996 (RCRA Online #14031)). Furthermore, when the laboratories or structures are owned by different people, the generator must obtain one identification number for each laboratory or structure even if the regulated activity is taking place on a contiguous piece of property (Monthly Report Question; February 1988 (RCRA Online #13129)). 

A generator may obtain an EPA ID by filing Form 8700-12, Notification of Regulated Waste Activity, with the appropriate EPA Regional or authorized state RCRA implementing agency. The notification forms are available from EPA Regional offices, state hazardous waste offices, or on the Internet at the following URL: http://www.epa.gov/epawaste/inforesources/data/form8700/forms.htm.
 
Additional guidance on EPA identification numbers is available in the following memos:
Memo, Petruska to Kuszaj; August 22, 1995 (RCRA Online #11916
Memo, Daneker to Kawatachi; August 3, 1983 (RCRA Online #11028)

Note: On November 28, 2016, EPA published the Hazardous Waste Generator Improvements Final Rule, which makes several revisions to the hazardous waste generator regulations. These revisions may affect the information provided in this FAQ. The final rule and additional information, including a fact sheet, frequent questions, and a webinar recording and slides, are available at www.epa.gov/hwgenerators/final-rule-hazardous-waste-generator-improvements.

The Hazardous Waste Generator Improvements Final Rule is effective on May 30, 2017; however, implementation in a particular state depends on the state’s authorization status. A discussion of the effect that this final rule will have on state authorization is available on page 85801 of the rule. Information about how the rule will affect the requirements in this FAQ in a particular state is best obtained from the state hazardous waste program. A list of state hazardous waste programs is available at www.epa.gov/hwgenerators/links-hazardous-waste-programs-and-us-state-environmental-agencies.

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