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Q&A: Is an Illinois Facility ID Number Required for a Company That Generates no More Than 100 kg of Special Waste per Month?

Q&A: Is an Illinois Facility ID Number Required for a Company That Generates no More Than 100 kg of Special Waste per Month?

A question from a former coworker (way back a looong time ago we both worked for a hazardous waste transportation and disposal company that no longer exists:  Laidlaw Environmental Services) on August 8, 2016:

Hey Dan, hope you are doing well.

Wondering what your take is on the whole IEPA ID system…….I was always under the impression that if a generator was in the State of Illinois, regardless of their generator status, they have to ship waste for disposal on a Uniform Haz Manifest. This would also include Non haz special waste. I just had a conversation with Hope Wright (IEPA) and she told me that ILCESQG are not required to ship on a Uniform Haz manifest, therefore, they are not required to have an IEPA Number. She indicated that it would not hurt them to have one, but not required…I guess my questions is do you agree with her? I appreciate any input.

Thanks Dan!

Always happy to help an old friend; my reply that same day:

She is correct.

A CESQG of hazardous waste (generates no more than 100 kg of hazardous waste in a calendar month) is not required to have a USEPA Identification Number or to use the Uniform Hazardous Waste Manifest per USEPA and Illinois EPA regulations.
In Illinois, a company that generates more than 100 kg of Class A special waste per month  must use the Uniform Hazardous Waste Manifest for its off-site transportation.
Class A special waste includes the following:
  • Hazardous waste.
  • Potentially infectious medical waste (PIMW).  A non-hazardous waste.
  • Industrial process waste.  Even if a non-hazardous waste.
  • Pollution control waste.  Even if a non-hazardous waste.

Therefore, a company would need to generate no more than 100 kg (220 lbs) of all hazardous waste and non-hazardous waste in a calendar month in order to be a CESQG of special waste in Illinois and therefore be exempted from the requirement to use the Uniform Hazardous Waste Manifest.

Even if a company believes it is below this threshold, transporters of special waste (which must be registered in Illinois) are hesitant to accept any shipment without a manifest for fear that the company is not a legitimate IL CESQG.

Non-special waste does not require the Uniform Hazardous Waste Manifest.
I hope this helps.
My answer was what he was looking for:
I think it does. Thanks Dan, you’re still the man!!

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