The US EPA requires you to submit a Notification of Regulated Waste Activity (8700-12) Form for certain activities involving wastes subject to the regulations of the Resource Conservation and Recovery Act (RCRA).  A Notification is required if you handle a regulated waste or hazardous secondary material and may be required under the following circumstances:

• You are a Large Quantity Generator (LQG) or Small Quantity Generator (SQG) of hazardous waste.  A Conditionally Exempt Small Quantity Generator of hazardous waste (CESQG) is not required to notify.
• You are a Large Quantity Handler of universal waste (accumulate >5,000 Kg of universal waste).
• You recycle hazardous waste.
• You transport, process, or re-refine used oil; burn off-spec used oil for energy recovery; or market used oil.  The generation, storage, and off-site transportation of used oil is not subject to notification.
• You are an eligible academic entity opting into 40 CFR 262, Subpart K.
• You are managing a hazardous secondary material.

Upon receipt of an initial notification form, your site will be issued a unique EPA ID number by the US EPA.  This number is specific to the geographic location of your site and does not change if you sell the property or expire if you go out of business.

If you already have an EPA ID number, you must submit a subsequent notification for changes in any of the following:

• Ownership.
• Hazardous waste generator status.
• Regulated waste activity.
• Universal waste handler status.
• Used oil handling.
• Facility contact person.

The Notification of Regulated Waste Activity Form is the method the US EPA or your state environmental agency (see below) relies on to track your regulated waste activities.  It is your responsibility to ensure the information they have is up-to-date, accurate, and complete. The US EPA recently updated its Notification of Regulated Waste Activity Instructions and Form Booklet in December 2011 and it contains very helpful information.

Many states with authorized hazardous waste programs have their own procedures and requirements for submittal of the initial and subsequent notification forms.  State-specific regulations may include:

• A state-specific notification form in lieu of the federal form.
• Time lines for submittal of the initial and subsequent notifications.
• If using the US EPA form, a state mailing address for submittal.
• Fees to accompany the notification.

It is very important that you check with your state to ensure your submittal meets their requirements.  

My training services cover the hazardous waste regulations of the US EPA and the HazMat Employee regulations of the US DOT.  I provide open enrollment training events nationwide and year round (my schedule) and on-site training to meet your exact needs.  Please contact me to arrange for the exact training services you require.