When to Notify EPA of Changes in Hazardous Waste Activities [40 CFR 262.12, 261.5]

May 31, 2018
If you are a generator of hazardous waste, 40 CFR 262.18 requires you to obtain an EPA identification number prior to offering your hazardous waste for transportation off-site. If you are a very small quantity generator (VSQG), you are not subject to this notification requirement as long as you comply with all the requirements of 40 CFR 262.14.
 
The RCRA Subtitle C Site Identification Form (known as EPA Form 8700-12) is the EPA form used to obtain your ID number as well as make initial and subsequent notifications of regulated waste activities that occur at your site. What if you obtained an ID number years ago and the information on the form is out of date? You can resubmit the form to keep your site information current. The most common reasons that hazardous waste generators must update the 8700-12 are on the excerpt from the form below.
 
1. Reasons for EPA Form 8700-12 submittal included on the form (you may select only one)
Obtaining or updating an EPA ID number for an on-going regulated activity that will continue for a period of time (includes hazardous secondary material, HSM, activity)
Submitting as a component of the Hazardous Waste Report for __________ (Reporting Year)
 
 □ 
Site was a TSD facility and/or generator of > 1,000 kg of hazardous waste, > 1 kg of acute hazardous waste, or > 100 kg of acute hazardous waste spill cleanup in one or more months of the reporting year (or State equivalent LQG regulations)
Notifying that regulated activity is no longer occurring at this Site
Obtaining or updating an EPA ID number for conducting Electronic Manifest Broker activities
Submitting a new or revised Part A Form
 
Unless your site already has an EPA identification number for its hazardous waste activities, when you first complete this form, EPA will issue your site a unique EPA ID number. If there is a change in the information you provided in your initial filing (e.g., change in ownership, change in generator status, new regulated waste activity, etc.), you must complete a subsequent notification in which you amend the information you previously submitted.
 
In 2016, the EPA published the Hazardous Waste Generator Improvements Rule which amended the form to include two new notification requirements for episodic generation and large quantity generators (LQG) receiving waste from very small quantity generators (VSQG) under the control of the same person.
 
13. Episodic Generation
 □ Yes
 □ No
Are you a SQG or VSQG generating hazardous waste from a planned or unplanned episodic event, lasting no more than 60 days, that moves you to a higher generator category? If “Yes,” you must fill out the Addendum for Episodic Generator.
14. LQG Consolidation of VSQG Hazardous Waste
 □ Yes
 □ No
Are you an LQG notifying of consolidating VSQG Hazardous Waste Under the Control of the Same Person pursuant to 40 CFR 262.17(f)? If “Yes,” you must fill out the Addendum for LQG Consolidation of VSQGs hazardous waste.
 
If your site’s generator status changes permanently you must update the notification. However, the new episodic generation rules allow generators to maintain their current status under some circumstances. (To learn more about how to determine your hazardous waste generator status, see Environmental Resource Center’s February 8, 2018, Reg of the Day™. To learn more about managing episodic hazardous waste, see our February 15, 2018, Reg of the Day™.)
 
A notification must be made regardless if your status is permanently changing or you are taking advantage of the episodic generation reduced regulations. This includes VSQGs who don’t need to notify under normal circumstances, but if episodic hazardous waste is generated then a notification is required.
 
The Hazardous Waste Generator Improvements Rule also added regulations for large quantity generators who consolidate and manage hazardous waste from VSQGs who are under the same control or ownership as the LQG. If a facility intends to accept waste from a VSQG, a notification must be made on EPA Form 8700-12 as well.
 
Some states use a state-specific form in place of EPA’s Form 8700-12, and their own deadlines for submitting or revising their form. Check with your state to determine if there are state-specific requirements, and refer to the State Contacts list posted on EPA’s website to determine where to send this notification.
 
Learn more about how to comply with the latest hazardous waste regulations by attending Environmental Resource Center’s Hazardous Waste Management (RCRA): The Complete Course seminar or Texas or California specific seminars, Hazardous Waste Management: Complete Course – Webcast, California Hazardous Waste Management – Webcast, or Hazardous Waste Management: Annual Update – Webcast.
 
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RCRA Hazardous Waste Management – Annual Update – June 13, July 10, July 31
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DOT/IATA: How to Ship Dangerous Goods by Ground & Air – June 19
IMDG: How to Ship Dangerous Goods by Vessel – June 20
How to Ship Batteries by Ground & Air – July 12
OSHA GHS Hazard Communication Standard – July 13
Underground Storage Tank (UST) Regulations – July 16
RCRA Hazardous Waste Management – The Complete Course – July 17
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IATA: How to Ship Dangerous Goods by Air – The Complete Course – July 19
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