Your Environmental Emergency Requires an EPA Provisional Identification Number—And More!

Perhaps your business or enterprise doesn’t normally produce hazardous waste. But that doesn’t mean the intricate requirements of hazardous waste management couldn’t suddenly be thrust upon you.

If deemed an environmental hazard, a spill or other kind of emergency can set into motion the regulatory prerogatives of the EPA; and what’s totally benign in moderation can be classified as needing hazardous material disposal when in overabundance: spilled milk comes to mind.

Removing what the EPA deems to be hazardous waste from your site—and transported to a state or federally regulated hazardous waste management, treatment, or storage facility—will require you to obtain an EPA identification number. There are two types:

You likely don’t have the first kind: A permanent number, for locations where hazardous waste is managed from ongoing operations. The second kind is what you will need: A provisional number, for locations that need to dispose of hazardous waste right away due to an emergency.

How to Get Your EPA Provisional ID Number

Obtaining a provisional ID number for hazardous waste removal requires calling your EPA regional office and providing such details as:

• Site of spill/accident
• Responsible party
• Mailing address
• Description of incident
• Materials involved and quantity
• Generator status (Is it still leaking, etc.)
• Cleanup contractor
• Transporter company name
• Transporter EPA ID number

The EPA will assign a Provisional Identification Number that will allow you to dispose of hazardous waste for 30 days.  However, other reporting requirements might apply, for which many states maintain a telephone hotline that should probably be in your Rolodex®—or its modern day equivalence.

Don’t forget the National Response Center

You will also want to contact the National Response Center (NRC), the single federal contact point for reporting oil and chemical spills. Operating 24/7and 365 days a year—it’s the place to call after 5:00 PM and on weekends, when EPA offices are closed.

Identification Numbers for Transporters

Bear in mind that the company you hire to transport the hazardous waste from your site also must have its own permanent EPA identification number. Transporters are forbidden from hauling hazardous waste if they are not so registered with the EPA.

EPA identification numbers for transporters are issued to their company headquarters, meaning each individual truck hasn’t its own unique number. Instead, it’s identified by the number issued to the overall company.

This is to facilitate the hazardous waste manifest, which is a protocol for tracking the hazardous material from the time it leaves your facility until it reaches the state or federally approved storage, treatment, or disposal site you’ve contracted to receive it.

Upon receiving the hazardous waste, the transporter must sign and date the manifest, acknowledging its receipt, and provide you a copy before leaving your premises.

Summary

Even though your enterprise does not normally produce hazardous waste, an accidental spill or other kind of emergency on your site can be deemed an environmental hazard by the EPA, thereby requiring hazardous waste management on your part.

You must move quickly to remediate the situation, but perhaps paradoxically, the EPA requires that you first obtain a provisional identification number before moving forward.  This is to trace your efforts and ensure that they conform to state and federal legal and regulatory guidelines.

Your first step is to contact your EPA regional office to request the provisional number and provide them with pertinent details about the emergency. You should also report the incident to the National Response Center.

Also remember that the company (although not the truck) you hire to transport the hazardous waste must have its own permanent EPA identification number. And as in all matters relating to hazardous waste handling and removal: expert consultation is crucial.

To learn more about our Emergency Spill Response Program call 800-936-2311.