Completing EPA Form 8700-12 “Notification of Hazardous Waste Activity” is what’s required. (Note that other handlers of hazardous waste including hazardous waste transporters, recyclers, and owners or operators of treatment, storage and disposal facilities (TSDFs) must also have an EPA ID number.)
It’s easy to determine whether you’re a hazardous waste transporter, recycler, or TSDF, but sometimes less obvious as to whether your business generates hazardous waste. Hazardous wastes are generated from many different chemical products, types of businesses, and activities. Often, businesses that use, manufacture, or handle the following generate hazardous waste:
- Petroleum products
- Paints, dyes, printing inks, thinners, solvents, or cleaning fluids
- Pesticides, herbicides, insecticides, or rodenticides
- Materials that dissolve metals, paints, paper, or clothing
- Flammable or combustible materials
- Products that are accompanied by a shipping label or placard, indicating that the product is hazardous, corrosive, flammable, toxic, ignitable, or reactive
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You need to calculate the quantity of hazardous wastes generated each month and to inventory the total accumulation of hazardous waste on-site. This information will be the basis for your EPA generator categorization. How much hazardous waste you can keep on-site and how long you can accumulate it will depend on this classification. Although each individual activity conducted at your facility may generate quantities of hazardous wastes under the reporting threshold, you must remember that the reporting threshold is based on the total quantity of hazardous waste generated each month.
EPA ID numbers are issued on a per-site basis. This means, for example, if a business has two sites where hazardous waste is generated, both sites must have their own EPA ID number. It also means that you must obtain a new EPA ID number if your business moves to a new location.
To obtain an EPA ID number, you must complete the federal “Notification of Hazardous Waste Activity” Form 8700-12, which may be provided to you by EPA or your state environmental agency.
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Although not indicated in the RCRA regulations, the form’s instructions require you to submit a revised form when certain things occur. Among the events that trigger revising the form are:
- Your facility moves
- Ownership changes (including the addition or replacement of an owner)
- The type of regulated waste activity conducted at the facility changes
- You commence to market, transport, re-refine, process used oil or burn off-specification used oil for energy recovery
- The person you’ve listed on the form as your site’s contact person changes
- Your generator status changes
See tomorrow’s Advisor for a guide to counting your hazardous wastes to determine your generator classification.
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