Do I Need a EPA Identification Number?
1. What is a EPA ID Number?
EPA ID numbers are unique identification codes assigned to hazardous waste generators, transporters, and treatment, storage, and disposal facilities by the United States Environmental Protection Agency (EPA). These 12-character alphanumeric codes serve as a key part of the EPA’s hazardous waste tracking system, known as the Resource Conservation and Recovery Act (RCRA) program. Each EPA ID number identifies a specific location where hazardous waste is generated, handled, or disposed of. Obtaining an EPA ID number is a legal requirement for any entity that generates, transports, treats, stores, or disposes of hazardous waste, as it allows the EPA to monitor potentially dangerous materials and ensure compliance with environmental regulations. The ID numbers help the EPA maintain records, conduct inspections, and take enforcement actions if necessary to protect human health and the environment from improper hazardous waste management practices.
2. Who Requires a EPA ID Number?
Not every business that uses a waste transporter needs an EPA generator identification number. The EPA requires any facility that produces hazardous waste to obtain a generator ID number.
Any facility that produces hazardous waste must comply with federal and state regulations regarding transportation permits, authorizations, and quantity limitations based on generator size, especially for interstate waste shipments. Refer to 40 CFR Part 260 for more details. Below is a list on who requires a EPA ID number:
- Large Quantity Generators (LQGs) of hazardous waste: Facilities that generate 1,000 kg (2,200 lbs) or more of hazardous waste per month.
- Small Quantity Generators (SQGs) of hazardous waste: Facilities that generate between 100 kg (220 lbs) and 1,000 kg (2,200 lbs) of hazardous waste per month.
- Conditionally Exempt Small Quantity Generators (CESQGs): Facilities that generate less than 100 kg (220 lbs) of hazardous waste per month.
- Treatment, Storage, and Disposal Facilities (TSDFs): Facilities that treat, store, or dispose of hazardous waste.
- Transporters of hazardous waste: Companies or individuals that transport hazardous waste.
- Underground storage tank (UST) owners and operators: Facilities with underground storage tanks that store petroleum or hazardous substances.
3. Different Waste Generator Categories
Here is a list of all EPA waste generator categorizes:
Very Small Quantity Generator (VSQG):
- Generates 220 lbs. (100 kg) or less of hazardous waste per month
- May not need an EPA ID number, but some states require it
Small Quantity Generator (SQG):
- Generates more than 220 lbs. (100 kg) but less than 2,200 lbs (1,000 kg) per month
- Requires an EPA ID number
Large Quantity Generator (LQG):
- Generates 2,200 lbs. (1,000 kg) or more of hazardous waste per month
- Requires an EPA ID number
Conditionally Exempt Small Quantity Generator (CESQG):
- Generates less than 220 lbs. (100 kg) per month
- May not need an EPA ID number, but some states require it regardless of amount
The need for an EPA ID number can vary by state, even for very small or conditionally exempt generators.
4. Federal vs. State EPA ID Requirements
The Environmental Protection Agency (EPA) requires facilities that generate, transport, treat, store, or dispose of hazardous waste to obtain an EPA identification (ID) number. This federal EPA ID number allows the EPA to track and regulate the cradle-to-grave management of hazardous wastes. In addition to the federal EPA ID requirements, many states have their own state-specific hazardous waste regulations that may include additional state-level ID number requirements. The state ID numbers are typically required in addition to the federal EPA ID, and they allow state environmental agencies to monitor and enforce hazardous waste rules within their borders, which may be more stringent than the federal regulations in some cases. Facilities that handle hazardous wastes must comply with both the federal EPA ID rules as well as any applicable state-level ID and reporting requirements where their operations are located.
5. Must Knows for Federal EPA Identification Number
Review hazardous waste laws on generator requirements and on-site accumulation limits. Obtain the required EPA ID number before shipping any hazardous waste. Report your waste generator status to the federal government.
Large quantity generators must ship waste out within 90 days and pay taxes on the tonnage. The ID number is site-specific, so you’ll need a new one if you move. Treatment facilities can’t legally accept waste from generators without the proper ID number.
Transporting hazardous waste without the required manifest can cost $50,000 per day, per violation, plus possible jail time. The generator is responsible from origin to disposal, so ensure all involved parties are properly permitted.
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