EPA ID Numbers, Manifests, and Shipping Hazardous Waste
Once a waste stream is classified as hazardous, a different set of rules takes over. You need an EPA ID number to ship it. You need a manifest to track it. You need a permitted transporter and a destination facility authorized to receive the specific waste codes on your shipment. Every step is signed, every signature ties back to a responsible person at your facility, and every document has a retention clock attached to it.
Once a waste stream is classified as hazardous, a different set of rules takes over. You need an EPA ID number to ship it. You need a manifest to track it. You need a permitted transporter and a destination facility authorized to receive the specific waste codes on your shipment. Every step is signed, every signature ties back to a responsible person at your facility, and every document has a retention clock attached to it.
This piece picks up where the determination ends. For the classification step that comes before any of this, see our California hazardous waste determination guide. For the discharge-permit question (whether the stream can stay onsite and go to the sewer instead), see the industrial wastewater discharge permit pillar.
You Need an EPA ID Number Before You Ship
No facility in California can move hazardous waste off its property without the appropriate hazardous-waste identification number (a U.S. EPA ID or California ID number) assigned to that generator location. The number is site-specific. It belongs to the address, not the company. If you operate two facilities, you need two numbers. If you move locations, the old number does not follow you.
In California, DTSC (the Department of Toxic Substances Control) issues the ID through the federal application form (US EPA Form 8700-12, the same form used nationally since the state aligned with the federal process). Generators of federally-regulated (RCRA) hazardous waste receive a permanent EPA ID. Generators of California-only (non-RCRA) hazardous waste can apply for a permanent California ID for ongoing generation, or a provisional ID for a one-time event like a cleanout or a facility closure.
When we walk a facility for a gap assessment, the EPA ID is one of the first items we check, and one of the most common deficiencies we find. We have seen facilities ship under a corporate affiliate’s ID rather than their own, ship under an ID that lapsed years ago, or ship without one at all because a safety manager did not know one was required. In one case, retail staff were puncturing butane canisters and putting them in the trash because no one at the site had ever been told the waste needed an ID, a manifest, and a permitted hauler.
Generator Status Sets the Rules
Federal RCRA sorts generators into three tiers based on monthly hazardous waste volume. California layers its own categories on top, because the state’s hazardous waste universe (Title 22) is broader than the federal list. For the detailed comparison, see California vs. federal hazardous waste rules under Title 22 and RCRA.
| Generator status | What changes for you |
|---|---|
| Very Small Quantity Generator (VSQG) | Lowest federal volume tier. California adopted GIR Phase 1 in 2024 and now uses VSQG terminology, but California VSQGs are generally held to SQG standards. California still requires manifesting, a written determination, proper labeling, and a permitted disposal pathway for every hazardous stream. |
| Small Quantity Generator (SQG) | Manifest required for offsite shipments. On-site accumulation time limits apply. Emergency contact and basic training requirements. |
| Large Quantity Generator (LQG) | Full manifesting. Shorter accumulation periods. Biennial hazardous waste generator report. Contingency plan. Annual personnel training. |
Your status drives almost everything downstream: how long you can hold a container before it has to leave, what the labels and accumulation start dates must show, whether you owe a biennial report, and what training your team needs. A facility can cross from SQG to LQG because of a single process change or a one-time cleanout, and most do not realize it until an inspector points it out at the next CUPA visit (your local CUPA, which may be a fire department, county environmental health agency, or other local agency depending on the jurisdiction, handles these inspections at the county level).
The Uniform Hazardous Waste Manifest
The manifest is the chain-of-custody document that follows hazardous waste from your loading dock to its final disposal site. The federal Uniform Hazardous Waste Manifest is used for both RCRA and California non-RCRA shipments, with California-specific waste codes added where they apply.
A complete manifest captures:
- Your facility name, address, and EPA ID
- The transporter’s name and EPA ID
- The destination facility’s name, address, and EPA ID
- DOT shipping name, UN/NA number, hazard class, and packing group
- Waste codes (federal and California, as applicable)
- Quantity, unit, and number of containers
- Land Disposal Restriction (LDR) notification, when applicable (22 CCR §66268.7)
- A signature from a responsible party at your facility certifying that the description, quantity, packaging, and labeling are accurate
The signature matters. Whoever signs is certifying, under both federal and California regulation, that the shipment is correctly described, packaged, and ready for transport. That signature creates real liability. It should be someone with authority and training, not whoever happens to be at the dock when the truck arrives.
California operates on the EPA’s electronic manifest system (eManifest, inside RCRAInfo) for the system of record. Paper manifests still appear in some shipments, but returned copies, corrections, and historical lookups all flow through the electronic portal. If your facility is still treating manifests as a paper-only process, the eManifest workflow is a gap worth closing.
Picking the Transporter and the Destination
A hazardous waste transporter operating in California must hold a current state registration and a valid EPA ID. The destination facility (a treatment, storage, and disposal facility, or TSDF) must be permitted to accept the specific waste codes on your manifest. Sending a stream to a TSDF that is not authorized for that code is a violation, and the burden of vetting the transporter and the destination sits with you as the generator. California’s hauler selection rules are written into 22 CCR §66263.10 and the related sections.
The most common shipping deficiencies we see in the field:
Missing or expired LDR notifications attached to the manifest
Mismatches between the manifest description and the DOT shipping paper
Container labels that do not match the manifest contents
Accumulation-start dates missing from labels, which can push a facility past its allowed storage time without anyone noticing
Waste codes copied from an old determination after the process changed
What You Keep, and for How Long
The generator’s recordkeeping obligation runs longer than most facilities assume. Keep manifests, LDR notifications, waste determinations, training records, inspection logs, and biennial reports together and accessible. The federal floor for many of these records is three years; we recommend five years or more for determinations, because a CUPA inspection or a DTSC enforcement action can reach back further than the minimum retention window.
Determinations sit at the foundation of the entire shipping chain. If the determination is wrong, the waste codes are wrong. If the waste codes are wrong, the manifest is wrong. If the manifest is wrong, the disposal is wrong. Every determination we issue goes through senior technical review before it leaves the office, in part because the documents that follow it depend on it being right the first time.
Trusted throughout California
BSY started working with CDMS last year after our in-house EHS person departed the company. CDMS reviewed our existing operational permits as well as any additional Federal, State and Local regulations that could apply and helped us to create a comprehensive compliance calendar to track regulatory deadlines and submittal due dates. The CDMS team does an excellent job of tracking everything and can be relied upon to complete the forms accurately and assist with submittals, allowing me to focus on our business.
Speak with a CDMS EHS expert
Tell us about your facility and your deadline. You’ll get a clear read on what applies and a scoped plan to handle it.