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EPA ID Number
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EPA ID Number

Hazardous waste handlers in California must obtain an EPA ID Number in order to comply with federal RCRA regulations as well as California regulations including the California Code of Regulations Title 22 and the California Health and Safety Code Chapter 6.5.

CDMS provides services to assist hazardous waste generators, transporters, treaters, storers, and disposers in determining the appropriate EPA ID to apply for, handling the application and setup process, reactivating deactivated IDs, maintaining valid IDs, ensuring correct usage, and meeting notification requirements for our customers in ongoing compliance programs.

Regulatory bodies
  • EPA (Environmental Protection Agency)
  • DTSC (Dept. of Toxic Substances Control)
  • CalEPA (California Environmental Protection Agency)
  • Local CUPAs (Certified Unified Program Agencies)
Who needs it

According to the Department of Toxic Substances Control (DTSC), anyone who generates, transports, offers for transport, treats, stores, or disposes of hazardous waste must have a hazardous waste identification (ID) number, which is used to identify the hazardous waste handler and track the hazardous waste from the point of origin to its final disposal (“cradle to grave”).

Regulation reference
  • Federal RCRA regulations (40 CFR Part 260-299).
  • California Health and Safety Code Chapter 6.5.
  • California Code of Regulations, Title 22, Division 4.5.
What our service provides:

CDMS provides the following services related to EPA Identification Numbers:

  • Determines the right EPA ID to apply for (federal vs state) based on your facility.
  • Handles the EPA ID application and setup process.
  • Assists with reactivating EPA IDs that have been deactivated.

 

For customers in our ongoing compliance program:

  • Maintains your EPA ID and ensures it remains valid.
  • Notifies you of any updates needed to stay compliant.
  • Oversees correct EPA ID usage for hazardous waste.

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Contact us

Who needs an EPA ID Number in California?

Any business generating hazardous waste over 100kg/month or 1,000kg accumulated at any time. Transporters, storers, treaters, and disposers of hazardous waste also need one.

 

How do I get an EPA ID Number for my company in California?

Apply to the DTSC online portal and provide information on your hazardous waste activities. Please Contact Us to get support to obtain the EPA ID Number for your facility. Our skilled team of EH&S specialists with extensive experience would be pleased to help you.

 

Is there a fee to obtain an EPA ID Number in California?

No, there is no fee associated with getting an EPA ID Number from Department of Toxic Substances Control (DTSC).

 

Can I operate without an EPA ID Number while waiting for approval?

No, facilities must have a valid ID number before conducting hazardous waste management activities.

 

What are the main differences between Temporary and Permanent EPA ID Number?

The Department of Toxic Substances Control (DTSC) provides options for obtaining both permanent and temporary EPA ID Numbers. Permanent EPA ID Numbers are issued to businesses or individuals who routinely generate or handle hazardous waste.

On the other hand, Temporary EPA ID Numbers are available for those who do not routinely generate hazardous waste or have one-time or short-duration events, such as asbestos abatement or the removal of underground tanks. These temporary ID numbers are valid for 90 days and cannot be renewed, but they underscore the requirement to have an EPA ID number before shipping hazardous waste to a recycler or disposal facility​​​​.

 

My EPA ID Number is for one facility. Can I use it for other sites?

No, you cannot use an EPA ID Number issued for one facility at other sites. According to the California Department of Toxic Substances Control (DTSC), each facility where hazardous waste is generated requires a separate EPA ID Number. EPA ID Numbers are site-specific (and in the case of State EPA ID Numbers, also owner-specific), meaning that they are tied to the physical location and, in some cases, the business owner of the site generating hazardous waste​​.

If your business generates waste at multiple addresses that are not physically connected (contiguous), each address needs a separate EPA ID Number. Similarly, if generators are independent businesses operating in suites within the same building, each business must have its own EPA ID Number.

 

 

I am transporting hazardous waste. Do I need a California EPA ID Number?

Yes, transporters based in California must obtain a California EPA ID number starting with “CAL”. Out-of-state transporters use their home state’s ID number.

 

Can I use my EPA ID Number for multiple activities?

Yes, you can use your EPA ID Number for multiple activities related to hazardous waste. The EPA ID number is used to ensure that hazardous and nonhazardous waste is properly transported and disposed of from start to finish, or what’s known as the “cradle-to-grave” process.

However, it’s important to note that the EPA ID numbers are site-specific and not business-specific. If you have a business that generates waste at multiple addresses that are not physically connected (contiguous), each address needs a separate ID number. In the case where generators are independent businesses that operate in suites within the same building, each business must have their own ID number.

 

What are the differences between State EPA ID Numbers and Federal ID Numbers?

California State EPA ID numbers are issued to people and businesses who generate the following:

  • Less than 100 kg (220 pounds / about 27 gallons of liquid volume) of RCRA hazardous waste per month.
  • Less than 1 kg of RCRA acutely hazardous waste per month.
  • Any amount of a non-RCRA hazardous waste per month.

 

Federal EPA ID numbers are issued to handlers of RCRA (federal) hazardous waste. If you or your business generates more than 100 kilograms of RCRA hazardous waste and/or more than 1 kilogram of RCRA acutely hazardous waste per month, you will need to obtain a federal EPA ID number. Federal EPA ID numbers are site specific.

 

Do I need a U.S. EPA ID Number, or a California ID Number?

If you generate more than 1 kilogram of RCRA acutely hazardous waste per month or more than 100 kilograms of other RCRA waste per month, you must get a U.S. EPA ID Number. If you generate 100 kilograms or less of RCRA waste or one kilogram or less per month of acutely hazardous waste, and meet certain other requirements, you are exempted by U.S. EPA from many of its regulations, including the requirement to have an EPA ID Number. These businesses are called “conditionally exempt small-quantity generators”, or CESQGs, according to 40 CFR section 261.5.

However, California regulations do not have an equivalent small-quantity generator exemption. Almost all business generators of hazardous waste in California that are not required to have a U.S. EPA ID Number must, in practice, have a California ID Number.

 

Exemptions:

  • Generators handling only hazardous waste produced incidental to owning and maintaining their own place of residence do not need an ID Number, either federal or state.
  • Businesses whose ONLY hazardous waste generation is 100 kilograms or less per month of waste that is hazardous solely because of its silver content (“silver-only waste”) do not need an ID Number. This is true even if they treat the waste in silver recovery units and then send the silver for reclamation.
  • Businesses that generate ONLY universal waste (fluorescent lamps, batteries, mercury wastes, etc.) and manage it as such also do not need an ID Number.

In summary, except for the above-mentioned exemptions, if you generate only non-RCRA hazardous wastes, or you generate less than 100 kilograms of RCRA hazardous waste per month (or less than 1 kilogram of RCRA acutely hazardous waste), you must get a California ID Number. If you generate more than 100 kilograms of RCRA waste per month or more than 1 kilogram of RCRA acutely hazardous waste per month, then you must get a U.S. EPA ID Number.

 

Do I have to display the EPA ID Number on my vehicles?

Facilities must have EPA ID prominently visible near entrance. Vehicles used to transport hazardous waste in California must display the name or trademark of the firm, legible from a distance of 50 feet during daylight, on each side of the vehicle or container. This requirement ensures that the vehicles are easily identifiable and compliant with California regulations for hazardous waste transportation​.

 

My business changed names. Do I need to update my EPA ID number?

Yes, if your business changes its name, you need to update your EPA ID number information. According to DTSC regulations, a registered hazardous waste transporter must notify DTSC within 30 days if there are changes to the transporter’s majority ownership, name, or location. This requirement ensures that all information related to the EPA ID number remains current and accurate, facilitating proper tracking and management of hazardous waste.

 

What are the penalties for not having the proper EPA ID number?

Not having the proper EPA ID number for handling hazardous waste can lead to regulatory non-compliance, resulting in potential fines and penalties. Specific penalties would depend on the nature and severity of the violation, as governed by the Department of Toxic Substances Control (DTSC) and applicable federal regulations.

 

Can my EPA ID Number ever be revoked?

Yes, Department of Toxic Substances Control (DTSC) can revoke EPA ID numbers in cases of serious, repeated non-compliance with state hazardous waste regulations after sufficient notice.

 

Additionally, the annual Verification Questionnaire (EVQ) for hazardous waste ID numbers and hazardous waste manifests is required by Health & Safety Code section 25205.16. Any generator, transporter, or facility operator who fails to provide information required by the department to verify the accuracy of hazardous waste activity data shall be subject to suspension of any and all identification numbers assigned and to any other enforcement action (Health & Safety Code section 25205.16(c)).

 

If your facility has the EPA ID Number inactive or revoked, please Contact Us. Our skilled team of EH&S specialists with extensive experience would be pleased to help you.

 

Can anyone access my EPA ID number or application information?

ID numbers are considered public information. Department of Toxic Substances Control (DTSC) may provide them upon request. More detailed application data can remain confidential if claimed.

 

I submitted my application but have not heard back. What should I do?

Please Contact Us if you need support regarding the status of your EPA ID Number or if you require guidance on the next steps to take.