The RCRA Subtitle C Site Identification Form (EPA Form 8700-12) is the federal form that businesses use to tell the U.S. Environmental Protection Agency (EPA) they generate, transport, treat, store, or dispose of hazardous waste, and to get or update an EPA Identification (EPA ID) Number. Any large or small quantity generator of hazardous waste must file it, and many other handlers must file it too. You submit the form to your state environmental agency, or to the EPA regional office when your state is not authorized to run the RCRA Subtitle C program.
Getting this form wrong is not a small problem. The Resource Conservation and Recovery Act (RCRA) lets regulators issue civil penalties that can reach into the tens of thousands of dollars per day, per violation, and operating without a valid EPA ID Number can shut down your waste shipments. The form looks short, but the wrong box, a missing waste code, or a P.O. Box in the wrong field can stall your registration for weeks. The good news is that once you understand each item, most filers finish the form in about 15 minutes, based on the official EPA instructions.
Here is what you will learn in this guide:
- 📋 What Form 8700-12 is, who must file it, and the law that requires it
- 🗂️ The exact documents and ID numbers to gather before you open the form
- ✍️ A line-by-line walkthrough of all 19 items, with sample entries
- 🏭 Three full filer scenarios, from an auto body shop to a hospital
- ⚠️ The mistakes that trigger rejections, holds, and penalties
What the Form Is and Who Must File It
EPA Form 8700-12 is officially called the Notification of RCRA Subtitle C Activities (Site Identification Form). It carries OMB Control Number 2050-0024, and it is the single intake document EPA and the states use to track every site that handles hazardous waste. The form collects your site name, address, contact details, the type of waste activity you run, and the federal waste codes you generate. Always confirm you have the current version before you file, since EPA updates the form and its instructions and posts the latest copy on the EPA generators page.
The form exists because RCRA, the federal hazardous waste law, requires EPA to know who is making and moving dangerous waste. The agency that receives the form is your authorized state environmental agency in most states, or an EPA regional office in states that are not authorized. The statute behind it is RCRA, carried out through the federal rules in 40 CFR Part 262 for generators. The deadline depends on your activity, and the penalty for skipping it can include fines and orders to stop operating.
You must file Form 8700-12 if any of these describe your site:
- You are a Large Quantity Generator (LQG), generating 1,000 kg or more of hazardous waste in a month
- You are a Small Quantity Generator (SQG), generating between 100 kg and 1,000 kg in a month
- You transport hazardous waste, or treat, store, or dispose of it (a TSDF)
- You manage hazardous waste pharmaceuticals under 40 CFR Part 266 Subpart P
- You handle universal waste at high volumes, recycle hazardous secondary materials, or act as an electronic manifest broker
A Very Small Quantity Generator (VSQG), generating less than 100 kg a month, usually does not have to file, but may choose to register, for example to gain benefits under Subpart P, as explained by HFM Magazine. SQGs must re-notify every four years to stay in compliance.
Before You Start: Documents and Information You Need
Filling out Form 8700-12 goes fast when you gather your facts first. Hunting for a NAICS code or an owner’s legal name in the middle of the form is where mistakes creep in. The form asks for legal identities, codes, and contact details that often live in different departments, so pull them together before you open the first page. This pre-filing checklist covers the core items most filers need.
- Your existing EPA ID Number, if you have one. You need it for Item 2 and the top of every page; leaving it off a subsequent notification breaks the link to your site record.
- The site’s legal name and operating name. These can differ, and the legal name points to the entity that owns the land, which your accounting team can confirm.
- The physical site location address. Item 4 will not accept a P.O. Box, so a missing street address stops the filing cold.
- The mailing address. This can be a P.O. Box and may differ from the location address, which matters for where notices reach you.
- Owner and operator legal names and contact info. Item 9 requires all of them; missing an owner can make the certification invalid.
- Your NAICS code(s). Item 7 needs a six-digit North American Industry Classification System code that matches your primary function, and the wrong code can misclassify your site.
- Your federal hazardous waste codes. You need every applicable F, K, P, U, and D code, since an incomplete list in Item 10 understates your waste profile.
- Your generator status. Know whether you are an LQG, SQG, or VSQG, because the wrong status changes the rules that apply to you.
- The name and title of an authorized signer. Item 19 must be signed by an officer or someone authorized in writing, or the form is not valid.
- Your state’s filing rules. Some states require a state form or electronic filing, so check before you pick paper, as noted by the New Mexico Environment Department.
Where to Get the Form and How to Access It
You get the official form straight from EPA. The agency packages Form 8700-12 inside a larger PDF that also holds the Biennial Report (Form 8700-13A/B) and the Part A Permit Application (Form 8700-23), but EPA also posts a shorter “Site Identification Forms and Instructions Only” PDF on the hazardous waste generators page. Download the Site ID excerpt if you only need to notify, since the full packet runs over 2 MB and includes forms you will not use.
You have two main ways to access and complete the form. The first is electronic, through EPA’s myRCRAid module inside the RCRAInfo Industry Application. The second is paper, by downloading the fillable PDF, completing it, and mailing it with an original signature to your state or EPA regional office. EPA encourages electronic filing, and a growing number of states have “opted in” to myRCRAid, with some now requiring it.
Check your state first, because the access path is not the same everywhere. Many authorized states accept the federal form, while others use their own version or mandate electronic submission. For example, Pennsylvania directs filers through its electronic process, and Nevada explains its own EPA ID Number steps. If your state is not authorized, you file with the EPA regional office that covers you.
Step-by-Step: How to Fill Out Form 8700-12 Line by Line
The form is one page of core fields, numbered Item 1 through Item 19, plus optional addendums. Complete it electronically or in black ink, mark choices with an X, and put your EPA ID Number in the top left corner of every page. If this is your first notification and you have no EPA ID Number yet, leave that corner blank. Work through the items in order, since later items build on earlier ones.
Item 1: Reason for Submittal
This item asks why you are sending the form right now. You mark one box that matches your situation, such as obtaining a first EPA ID Number, updating an ongoing activity, or submitting an SQG re-notification. Mark the box for “Obtaining or updating an EPA ID Number for an ongoing regulated activity that will continue for a period of time” if you are a continuing operation.
For example, Maria Delgado, who is opening a new auto body shop, marks the box for a first-time notification to obtain an EPA ID Number. A common edge case is the SQG four-year re-notification, which has its own box and is easy to overlook. The most common mistake here is leaving Item 1 blank or guessing, which sends the form into manual review and delays your ID Number. Many filers wrongly believe this box is optional; it is the first thing the reviewer reads, and the rest of the form is interpreted through it.
Item 2: Site EPA ID Number
This field asks for the EPA Identification Number already assigned to your physical site. You enter the full number, and the first two characters must be a valid state postal code, such as CA for a California site. Westside Auto Body in San Francisco would start its number with CA.
If this is your initial notification for the site, leave this field blank, because EPA assigns the number after it processes your form. The most common mistake is typing a company-wide or corporate number that belongs to a different location, which links your filing to the wrong site record. People often think one EPA ID Number covers a whole business; in reality, the number is tied to the specific physical address, so each site needs its own.
Item 3: Site Name
This item asks for the name your site operates under day to day. You write the operating name, which customers and staff would recognize, in plain text. For example, Riverbend Community Hospital enters that exact operating name.
Note that the site name can differ from the legal owner name you list later in Item 9. A common edge case is a facility that recently rebranded but still holds older permits under a prior name; use the current operating name here and explain any change in the comments. The frequent mistake is entering the parent corporation’s name instead of the site’s name, which confuses regulators about which location is reporting. Some filers assume this must match their tax documents exactly; it should match how the site actually operates.
Item 4: Site Location Address
This field asks for the real, physical street address where the hazardous waste activity happens. You enter the full street number, street name, city, state, and ZIP code. Westside Auto Body writes 1422 Folsom Street, San Francisco, CA 94103.
You may not use a P.O. Box here, because regulators and inspectors must be able to find the actual site. A common edge case is a large campus with several buildings; use the address that best identifies the regulated operation. The most damaging mistake on this line is entering a P.O. Box or a mailing center, which can invalidate the filing and block an inspection. Many filers think a mailing address is good enough; the location address must be a place an inspector can physically visit.
Item 5: Site Mailing Address
This item asks where you want to receive mail about the site. You either check the “Same as location address” box or write a separate mailing address. Riverbend Community Hospital might check the box, while a shop that gets mail at a separate office writes P.O. Box 5567, San Francisco, CA 94119.
Unlike Item 4, this field allows a P.O. Box. A common edge case is a corporate office that handles all compliance mail for several sites; list that address so notices reach the right desk. The usual mistake is leaving it blank when the mailing address differs from the location, which means you may miss important notices and deadlines. People often assume mail goes to the physical site by default; if you skip this field, you risk missing letters that have hard deadlines.
Item 6: Site Land Type
This item asks who owns the land type your site sits on. You pick one option: private, county, district, federal, tribal, municipal, state, or other. A private business like Westside Auto Body marks Private.
Choose the most descriptive option when more than one seems to fit, such as county rather than municipal. A common edge case is a clinic on a county-owned medical campus, which would mark County. The mistake here is defaulting to private out of habit when the land is actually government owned, which misreports the site’s category. Some filers think this box is about who runs the building; it is about the land type, not the operator.
Item 7: NAICS Codes
This field asks for the North American Industry Classification System code that describes what your site does. You enter the six-digit code that best fits your primary function in box A, and additional codes after it. Westside Auto Body enters 811121 for automotive body and paint repair.
Use a six-digit code when one exists, or a five-digit code if needed, but never a four-digit code. A common edge case is a facility with several functions; list the primary one first, then secondary codes. The mistake of using a vague or wrong code can misclassify your industry and trigger questions from your reviewer. Many filers think any close code will do; the wrong code can flag your site for the wrong rules, so search the official NAICS list to confirm.
Item 8: Site Contact Information
This item asks for the person who handles RCRA hazardous waste questions for the site. You enter their name, title, phone, email, and address. Riverbend Community Hospital lists Tom Nguyen, EVS Director, (415) 555-0148, tnguyen@riverbendhosp.org.
This is usually the facilities manager or environmental services director, not a corporate attorney. A common edge case is when the person filling out the form is not the main contact; that person’s details go in Item 18 instead. The mistake of naming someone who has left the company means regulators cannot reach you, which can escalate a small issue into a violation. Filers sometimes assume this must be a top executive; it should be the person who actually knows the waste operations.
Item 9: Legal Owner and Operator of the Site
This item asks for every legal owner and operator of the site. You list each owner and each operator with their contact information and indicate the type of owner. If Harbor Realty LLC owns the land and Riverbend Community Hospital operates the facility, both are listed.
The date someone became an owner is optional, and you can use Item 18 or attached pages for extra owners, as long as the EPA ID Number appears in the top left corner of each added page. A common edge case is multiple owners; all must be listed, not just the largest. The mistake of leaving out an owner or operator can make the certification invalid and stall the form. People often confuse owner with operator; the operator is the party responsible for running the RCRA site day to day, even if a different company owns the land.
Item 10: Type of Regulated Waste Activity
This is the heart of the form, and it has three parts. In part A, you mark your hazardous waste activity, including your generator status of LQG, SQG, or VSQG, and whether you transport, treat, store, or dispose. In part B, you list all federal hazardous waste codes you generate, and in part C, you list any state-regulated wastes.
For example, a manufacturer that is an LQG marks Large Quantity Generator and lists codes such as D001 for ignitable waste and F003 for spent solvents in part B. A common edge case is hazardous waste pharmaceuticals managed under Subpart P, which do not need their waste codes listed in part B. The mistake of understating your generator status, or leaving out a waste code, misrepresents your operation and can lead to enforcement when an inspector finds the missing waste. Many filers think only “big” wastes count; even small streams with a D code must be listed.
Item 11: Additional Regulated Waste Activities
This item asks about waste activities beyond standard generation. You answer Yes or No for part A other waste activities, part B universal waste, part C used oil, and part D pharmaceutical activities. A hospital under Subpart P marks Yes in part D and checks Healthcare facility.
Most small generators mark No across most of part 11. A common edge case is a site that recycles large volumes of batteries or lamps and qualifies as a large quantity handler of universal waste, which would mark Yes in part B. The mistake of marking Yes for a high-volume universal waste handler when you are not one, or missing it when you are, misreports your obligations. Filers often assume recycling lamps automatically makes them a universal waste handler; the threshold is accumulating 5,000 kilograms or more.
Item 12: Eligible Academic Entities with Laboratories
This item asks whether your site is a college, university, or teaching hospital opting into the laboratory rule under 40 CFR Part 262 Subpart K. You mark Yes or No, and most filers mark No. A research university lab program might mark Yes.
A common edge case is a teaching hospital tied to a university, which may qualify. The mistake of marking Yes without meeting the definition pulls you into rules that do not fit your site. Some filers think any business with a lab qualifies; this item is limited to eligible academic entities, not ordinary company labs.
Item 13: Episodic Generation
This item asks whether you are using the episodic generation provision, which lets a VSQG or SQG handle a one-time or rare waste event without bumping up its generator category. You mark Yes or No, and most filers mark No. A VSQG doing a one-time tank cleanout might mark Yes and complete the episodic addendum.
A common edge case is a planned annual cleanout that pushes waste above your normal limit; the episodic rule can cover it if you follow the conditions. The mistake of skipping this when you rely on the provision means you lose the protection and may be treated as a higher-category generator. People often think any waste spike qualifies; the episodic event must meet specific limits and notification steps.
Item 14: LQG Consolidation of VSQG Hazardous Waste
This item asks whether your LQG site is consolidating hazardous waste from VSQGs you control. You mark Yes or No, and complete the consolidation addendum if Yes. A hospital system LQG that collects waste from small affiliated clinics marks Yes.
A common edge case is a company with one big site and several tiny satellite locations; the LQG can gather their waste under this provision from the Generator Improvements Rule. The mistake of marking Yes without filing the required addendum leaves the consolidation undocumented. Filers sometimes assume any waste pickup from another site qualifies; it only applies when the VSQGs are under the control of the same person and the addendum is filed.
Item 15: Notification of LQG Site Closure
This item asks whether you are notifying that an LQG is closing a central accumulation area or the entire facility. You mark Yes or No, and most active sites mark No. An LQG shutting down a storage area enters the closure dates here.
A common edge case is closing one accumulation area while the rest of the site keeps running; you note that partial closure here. The mistake of failing to notify a closure can leave you on the hook for ongoing requirements you no longer meet. Some filers think closure paperwork is separate from this form; for LQGs, this item is where the closure notice starts.
Item 16: Notification of Hazardous Secondary Material Activity
This item asks whether you generate, manage, or reclaim hazardous secondary materials under a recycling exclusion. You mark Yes or No, and complete the HSM addendum if Yes. A chemical plant reclaiming a solvent under the exclusion marks Yes.
A common edge case is a manufacturer that sends a byproduct off-site for legitimate recycling under the exclusion. The mistake of claiming the exclusion without filing the addendum can cost you the exclusion and reclassify the material as waste. Many filers assume any recycling earns the exclusion; it applies only to specific materials under defined conditions.
Item 17: Electronic Manifest Broker
This item asks whether you act as a broker in the EPA e-Manifest system, arranging hazardous waste shipments for others. You mark Yes or No, and most generators mark No. A third-party logistics firm that books manifests for clients marks Yes.
A common edge case is a consulting firm that handles manifests for several generators. The mistake of marking Yes when you only manage your own shipments overstates your role and may create reporting duties you do not have. Filers sometimes confuse using the e-Manifest system with brokering; brokering means arranging shipments for other parties.
Item 18: Comments
This item gives you space for any extra information that did not fit above, such as additional owners, extra waste codes, or a name change. You write the item number and box letter, then the detail. For example, you might note “Item 9 continued: third owner, Bay Industrial Trust.”
A common edge case is needing extra pages; you can attach them, but the EPA ID Number must appear in the top left corner of each one. The mistake of cramming overflow into the wrong field instead of using comments makes the form hard to read and can cause data entry errors. People often skip this field thinking it is decorative; it is the proper home for any answer that needs more room.
Item 19: Certification
This is the legal signature block, where an authorized person swears the information is true and complete. You sign, print your name and title, and date it. Tom Nguyen, EVS Director, signs and dates the form, and on paper it must be an original signature, not a photocopy.
Only a recognized authority can sign, and anyone else must be authorized in writing to the state director or EPA regional director beforehand. A common edge case is a consultant preparing the form; they cannot sign unless the company has authorized them in writing. The mistake of an unauthorized or missing signature voids the entire submission, since false certification carries serious legal penalties. Some filers treat this as a formality; signing here is a sworn legal statement.
Three Filled-Out Examples Using Real Scenarios
Seeing the form completed end to end helps more than reading the items alone. Below are three common filers walked through the key sections. Each shows what that person enters in the most important fields.
Scenario 1: Maria Delgado opens a new auto body shop (first-time SQG).
| Form Section | What Maria Enters |
|---|---|
| Item 1: Reason for Submittal | X on “Obtaining a first EPA ID Number” |
| Item 2: Site EPA ID Number | Left blank (initial notification) |
| Item 3: Site Name | Westside Auto Body |
| Item 4: Site Location Address | 1422 Folsom Street, San Francisco, CA 94103 |
| Item 6: Site Land Type | Private |
| Item 7: NAICS Code | 811121 |
| Item 9: Owner/Operator | Maria Delgado, owner and operator |
| Item 10: Waste Activity | SQG; codes D001, F005 |
| Item 19: Certification | Maria Delgado, signed and dated |
Scenario 2: Riverbend Community Hospital updates its ID for Subpart P pharmaceuticals.
| Form Section | What the Hospital Enters |
|---|---|
| Item 1: Reason for Submittal | X on “Updating an EPA ID Number for an ongoing activity” |
| Item 2: Site EPA ID Number | CAR000123456 |
| Item 3: Site Name | Riverbend Community Hospital |
| Item 4: Site Location Address | 900 Health Plaza Drive, Sacramento, CA 95814 |
| Item 7: NAICS Code | 622110 |
| Item 9: Owner/Operator | Harbor Realty LLC (owner), Riverbend Community Hospital (operator) |
| Item 10: Waste Activity | SQG; nonpharmaceutical codes only in part B |
| Item 11: Additional Activities | Yes, part D, Healthcare facility under Subpart P |
| Item 19: Certification | Tom Nguyen, EVS Director, signed and dated |
Scenario 3: Atlas Manufacturing files a subsequent notification as an LQG.
| Form Section | What Atlas Enters |
|---|---|
| Item 1: Reason for Submittal | X on “Subsequent notification / updating activity” |
| Item 2: Site EPA ID Number | TXD987654321 |
| Item 3: Site Name | Atlas Manufacturing Plant 2 |
| Item 4: Site Location Address | 5500 Industrial Parkway, Houston, TX 77032 |
| Item 6: Site Land Type | Private |
| Item 7: NAICS Code | 332710 |
| Item 10: Waste Activity | LQG; codes D001, D008, F003, F005 |
| Item 14: LQG Consolidation | Yes, with consolidation addendum attached |
| Item 19: Certification | Janet Pierce, Plant EHS Manager, signed and dated |
These five named filers, Maria, Tom, Harbor Realty, Atlas, and Janet, show how the same form flexes for very different sites. The fields that change most are Item 1, Item 10, and the addendums.
How to File the Completed Form
You can file Form 8700-12 through more than one channel, and the right one depends on your state. Below are the main options with the details you need for each.
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Electronic, through myRCRAid: Log in to the RCRAInfo Industry Application, select the myRCRAid module, complete the form, and sign electronically. There is no federal filing fee. Processing is often faster than paper, and your proof of filing is the on-screen confirmation and the submission record stored in your account.
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By mail, on paper: Download the fillable PDF, complete it in black ink, sign it with an original wet-ink signature, and mail it to your state agency or EPA regional office. There is no federal filing fee, though some states may charge their own fee. Processing can take several weeks, so keep a copy of the signed form and your certified mail receipt as proof.
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In person or by your state’s portal: Some states require their own electronic portal or accept hand delivery to a regional office. Fees, payment methods, and processing times vary by state, so confirm with your state before filing, and keep any stamped receipt the office gives you.
Because rules differ, always check where to send the form. EPA directs filers to contact their state or regional representative for the correct address, as noted on the EPA generators page. Keep your proof of filing in your compliance file, since you may need to show it during an inspection.
What Happens After You File
After you submit, the state or EPA reviews your form and, for a first-time filer, assigns your EPA ID Number. For initial notifications, the number arrives after processing, which is why Item 2 is blank when you start. Once you have the number, you can legally ship hazardous waste using manifests, since transporters and disposal facilities will ask for it.
Your filing becomes part of your permanent site record in the federal RCRAInfo system. Regulators use it to schedule inspections, track your waste codes, and confirm your generator status. If your information changes, such as a new contact, a new waste stream, or a closure, you file an updated Form 8700-12 to keep the record current.
Some obligations continue after filing. SQGs must re-notify every four years, and LQGs report through the Biennial Report in even-numbered years. If you ignore these follow-up duties, you can fall out of compliance even though your first filing was correct, which is a common trap for busy sites.
Mistakes to Avoid When Filling Out the Form
- Leaving Item 1 blank. The reviewer cannot tell why you filed, so the form goes to manual review and your ID Number is delayed.
- Using a P.O. Box in Item 4. The location address must be physical, and a P.O. Box can invalidate the filing.
- Entering a corporate EPA ID Number for one site. The number is site-specific, so the wrong number links your form to the wrong location.
- Filling in Item 2 on a first-time notification. EPA assigns the number, so a guessed number creates a duplicate or error.
- Picking the wrong NAICS code in Item 7. A bad code misclassifies your industry and can flag you for rules that do not apply.
- Understating generator status in Item 10. Calling an LQG an SQG hides obligations and invites enforcement when waste totals are checked.
- Omitting a waste code. A missing D, F, K, P, or U code understates your waste profile and can become a violation on inspection.
- Forgetting an owner or operator in Item 9. A missing party can make the certification invalid and stall the form.
- Using a photocopied signature on paper. Paper forms need an original signature, and a copy can be rejected.
- Having an unauthorized person sign Item 19. Only an authorized signer is valid, and a bad signature voids the whole submission.
- Skipping the SQG four-year re-notification. You fall out of compliance even if your first filing was perfect.
- Forgetting the EPA ID Number on attached pages. Extra pages without the number in the top left corner can get separated from your form.
Do’s and Don’ts
Do:
- Do gather your NAICS code, waste codes, and owner names first, because hunting for them mid-form is where errors start.
- Do check your state’s rules before you file, since many states require their own form or electronic submission.
- Do put your EPA ID Number in the top left corner of every page, so all your pages stay linked to your site record.
- Do use the comments in Item 18 for overflow, which keeps the main fields clean and readable.
- Do keep your proof of filing, because you may need it during an inspection.
- Do update the form when information changes, so your site record stays accurate and compliant.
Don’t:
- Don’t use a P.O. Box in the location address, because inspectors must be able to find the physical site.
- Don’t guess your generator status, since the wrong category applies the wrong rules and penalties.
- Don’t let an unauthorized person sign, because that voids the certification and the filing.
- Don’t skip waste codes to look cleaner, since omitted codes become violations when inspectors find the waste.
- Don’t assume one EPA ID Number covers every site, because each physical location needs its own.
- Don’t ignore re-notification deadlines, because falling out of compliance can bring fines even after a good first filing.
Pros and Cons of Filing on Your Own vs. With Help
Filing on your own (pros):
- It costs nothing extra, since there is no federal filing fee and no consultant bill.
- You learn your own waste profile, which helps you stay compliant long term.
- You control the timing, so you can file the moment you are ready.
- The form is short, and many filers finish it in about 15 minutes.
- You build a direct relationship with your state agency, which helps with future questions.
Filing with professional help (pros, and the cons of going solo):
- A consultant catches code and status errors, which reduces the risk of a costly mistake on your own.
- They know your state’s quirks, so they can handle state forms and portals you may not know.
- They can manage re-notifications and biennial reports, which busy sites often forget when filing solo.
- They reduce enforcement risk, since a wrong solo filing can lead to penalties.
- They save your staff time, which is the main downside of doing a complex multi-site filing yourself.
Filing Channel Comparison
| Filing by Mail (Paper) | Filing Online (myRCRAid) |
|---|---|
| Requires an original wet-ink signature | Uses a secure electronic signature |
| Processing can take several weeks | Often processed faster |
| Proof is your certified mail receipt | Proof is your on-screen confirmation and account record |
| Available everywhere the federal form is accepted | Available only in states that opted in, and required in some |
| Easy to misplace an attached page | All data stays in one digital record |
FAQs
Do I need an EPA ID Number if I only generate a tiny amount of waste?
No. A Very Small Quantity Generator under 100 kg a month usually does not need to file, though you may register to gain benefits like those under Subpart P.
Do I leave Item 2 blank on my first filing?
Yes. For an initial notification, you leave the EPA ID Number blank, because EPA assigns the number after it processes your form.
Do I write my P.O. Box in the Site Location Address in Item 4?
No. Item 4 must be a physical street address, since inspectors need to find the site; your P.O. Box can go in the Item 5 mailing address.
Do I list hazardous waste pharmaceutical codes in Item 10 part B?
No. A site operating under 40 CFR Part 266 Subpart P does not list waste codes for its hazardous waste pharmaceuticals in part B.
Do I enter the operating name or the legal name in Item 3?
Yes, the operating name. Item 3 is the day-to-day site name, while the legal owner name belongs in Item 9.
Do I have to list every owner in Item 9?
Yes. You must list all legal owners and operators, and you can use Item 18 or attached pages if you run out of room.
Do SQGs have to re-notify?
Yes. Small Quantity Generators must submit a re-notification every four years to stay in compliance.
Do I need a six-digit NAICS code in Item 7?
Yes when one exists. Use a six-digit code, or a five-digit code if needed, but never a four-digit code.
Do I have to file electronically?
No, unless your state requires it. EPA offers myRCRAid in states that opted in, and some states now mandate electronic filing.
Do I pay a fee to file Form 8700-12?
No. There is no federal filing fee, though a few states may charge their own fee for processing.
Do I need an original signature on a paper form?
Yes. Paper filings require an original wet-ink signature in Item 19; a photocopy can be rejected.
Do I use one EPA ID Number for all my company’s sites?
No. Each physical site needs its own EPA ID Number, because the number is tied to a specific location.
Do I mark Item 1 if I am only updating my contact information?
Yes. You still mark the reason for submittal that fits an update to an ongoing activity, then change the relevant fields.
Do consultants get to sign Item 19 for me?
No, not unless authorized in writing. A consultant may prepare the form, but only an authorized representative can certify and sign it.
Related reading
- How to Fill Out EPA Form 8700-12 (w/ Examples) + FAQs
- How to Fill Out EPA Form 8700-22 (w/Examples) + FAQs
- How to Fill Out the Washington Ecology Dangerous Waste Annual Report (RCRAInfo) + FAQs
- How to Fill Out the Ohio EPA Hazardous Waste Generator Report (Biennial Hazardous Waste Report): A Line-by-Line Guide + FAQs
- How to Fill Out the RCRA Hazardous Waste Part A Permit (w/Examples) + FAQs
- How to Fill Out the RCRA Hazardous Waste Part B Permit (w/Examples) + FAQs
- How to Fill Out the Washington Ecology Water Quality Modification Permit + FAQs