Does My Business Need Generator Identification Numbers and Manifests?

Information presented in this publication is intended to provide a general understanding of the statutory and regulatory requirements governing generator identification numbers and manifests. This information is not intended to replace, limit or expand upon the complete statutory and regulatory requirements found in the Illinois Environmental Protection Act and Title 35 of the Illinois Administrative Code of Regulations.

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Because you generate waste, it is your responsibility to determine how to properly manage and dispose of your waste. This fact sheet discusses special waste, who must obtain a generator identification number, and who must use uniform hazardous waste manifests, which are required for both nonhazardous and hazardous special waste. If you need additional information, see the contact information at the end of this fact sheet. Depending on the types and amounts of waste that you generate, you may need a U.S. Environmental Protection Agency (U.S. EPA) and/or Illinois Environmental Protection Agency (Illinois EPA) generator identification number. The first step in determining whether you need an identification number is to identify the types and amounts of waste you generate.

Do I Generate Special Waste?

Special waste includes hazardous waste, potentially infectious medical waste, industrial process waste and pollution control waste. To determine the type of waste you generate, call the Office of Small Business for further information and to receive a copy of the fact sheet“ Do I Have a Special Waste?” These wastes must be managed at a permitted facility regardless of the amount you generate. Only decertified special waste may be placed with regular trash.

Why is the Amount of Hazardous Waste Generated Important to Know?

Hazardous waste regulations are associated with three categories of hazardous waste generators. The categories are based on the amount of hazardous waste generated per month. In order to determine the specific requirements that must be met, you must first determine category of generator which your business is based on the amount of waste generated. The three categories of hazardous waste generators are listed below.

To determine your hazardous waste generator category, add up the weight or volume of all the hazardous wastes you generate per month. For more information on hazardous waste requirements, call the Office of Small Business to receive a copy of the fact sheet“ How Do I Manage My Hazardous Waste?” The quantity cannot be averaged, it must be determined each month.

GENERATOR IDENTIFICATION NUMBER

Do I Need a U.S. EPA Identification Number?

If you are an SQG or LQG of hazardous waste, you must obtain and use a U.S. EPA identification number. The U.S. EPA uses a 12-character number that starts with the postal code of the state in which the generator is located to monitor and track hazardous waste activities. You will need to use your identification number when you send hazardous waste off site for management and disposal.

Do I Need an Illinois EPA Identification Number?

If you generate over 100 kg (220 lbs) of any kind of special waste, you must obtain and use an Illinois EPA identification number. The state of Illinois uses this 10-digit number to monitor and track special waste activities. You will need to use your identification number when you send special waste off site for management and disposal.

Do I Need Identification Numbers for all of My Properties?

If you have waste-generating operations on contiguous properties, you are not required to obtain a U.S. EPA or an Illinois EPA identification number for each property. If your properties are not contiguous, you will be required to obtain a U.S. EPA and Illinois EPA identification number for each property. For further information, contact the Office of Small Business.

How Do I Get Identification Numbers?

To obtain the U.S. EPA identification number application, contact the Office of Small Business and ask for a copy of EPA Form 8700-12, “Notification of Hazardous Waste Activity.” You will be sent a booklet that contains a form with instructions. To complete these forms, you need to know the hazardous waste code for your hazardous waste. Waste codes are included in the instruction booklet. The U.S. EPA identification number application can also be found on U.S. EPA’s webpage at http://www.epa.gov/epaoswer/hazwaste/data/form8700/forms.htm.

To obtain the Illinois EPA identification number application, contact the Office of Small Business and ask for a copy of the “Illinois EPA Inventory Identification Number Application.” You will be sent a form with instructions. To complete this form, you need to know the North American Industry Classification System (NAICS) code for your business type. A list of NAICS codes will be included with the instructions. The Illinois identification number application as well as EPA 8700-12 can also be found on Illinois EPA’s webpage at www.epa.state.il.us/land/forms/#generator-forms.

Send both the U.S. EPA and Illinois EPA completed applications to the following address:

Both the U.S. EPA and Illinois EPA identification numbers stay with the property when ownership changes. If you move your business, you must notify Illinois EPA of your new location and submit new forms.

Uniform Hazardous Waste Manifests

Depending on the types and amounts of waste you generate, you may need to use uniform hazardous waste manifests to ship your special waste (hazardous as well as nonhazardous) from your facility.

What Is an Illinois Uniform Hazardous Waste Manifest?

The Illinois Uniform Hazardous Waste Manifest is a multicopy shipping document that tracks hazardous waste from its point of generation to the treatment, storage, and disposal facility (TSDF). The manifest is required by the U.S. Department of Transportation, U.S. EPA and Illinois EPA. It allows the waste generator to confirm that the waste has been properly delivered and that no waste has been lost or unaccounted for.

Who Uses Manifests?

All SQGs and LQGs of special waste, including hazardous, nonharzardous, pollution control and industrial process, must use an Illinois Uniform Hazardous Waste Manifest when shipping waste to an Illinois TSDF or when shipping waste to states not requiring their own manifests.

How Do I Get A Manifest?

After obtaining an Illinois EPA identification number, manifests may be ordered by mail, or by credit card on-line. The manifest request form, as well as the on-line order form, are available at http://epadata.epa.state.il.us/land/manifest-sales/ or by calling 217-785-8604. The manifests are $3.00 each and may be ordered in any quantity with no minimum or maximum order amount.

How Do I Complete The Uniform Hazardous Waste Manifest?

The manifest contains information on the type and quantity of waste being transported, instructions for handling the waste, and signature lines for all parties involved in the waste disposal process. The Illinois Uniform Hazardous Waste Manifest contains an original, plus five NCR copies. A description of who keeps each part is printed at the bottom of each page. The manifest completion process is summarized below:

What Do I Do If The TSDF Does Not Send The Manifest Back?

If a generator does not receive a copy of the manifest signed by the TSDF within 30 days of the date that the waste was accepted by the initial transporter, the generator should contact both the transporter and the TSDF to obtain a replacement photocopy. If this does not resolve the problem, the generator must file an exception letter with Illinois EPA within 60 days. The exception letter should be addressed to the Illinois EPA Bureau of Land - Solid Waste Management Section and state that your facility did not receive a signed copy of the manifest (Part 1) from the TSDF and include steps you have taken to attempt to resolve the problem.

REPORTING REQUIREMENTS

Depending on the type, amounts and destination of the waste you generate, you may be required to submit an annual waste report.

Do I Need to Submit an Annual Hazardous Waste Report?

If you are a hazardous waste large quantity generator or are a hazardous waste TSDF, you are required to file an “Annual Hazardous Waste Report” by March 1 of each year. Forms within the “Annual Hazardous Waste Report” that your business must complete are based on your generator size and on-site waste management status. Forms and instructions for completion are provided in the report or on Illinois EPA’s website at www.epa.state.il.us/land/forms.html.

Do I Need to Submit a Nonhazardous Special Waste Annual Report?

The Illinois Pollution Control Board has changed the 35 Ill. Adm. Code 809 rules.  This means that nonhazardous special waste generators will no longer have to submit a Nonhazardous Special Waste Annual Report for nonhazardous special wastes that are shipped out of state.  Because of other rules and provisions in the Act, there are no net changes to manifest requirements.

If you are a nonhazardous special waste TSDF and  receive waste from off site, you are required to file a "Nonhazardous Special Waste Annual Report" by February 1 of each year. 

For more information on submission of annual waste reports, contact the Office of Small Business.

Where Do I Go For More Information?

For additional information on hazardous waste and other environmental requirements, please call the Office of Small Business at 1-888-372-1996. All calls are considered confidential, and the caller can remain anonymous. You can also visit the Illinois EPA website at www.epa.state.il.us. All the fact sheets mentioned in this document are available through the Illinois EPA website.

TOGETHER WE CAN PROTECT AND ENHANCE THE ENVIRONMENT OF ILLINOIS