Starting the RCRA Subtitle C Site Identification Form

If an organization is currently a large quantity generator (LQG) or small quantity generator (SQG) of hazardous waste, including hazardous waste pharmaceuticals, the organization is required to participate in Subpart P. This includes submitting a “RCRA (Resource Conservation and Recovery Act) Subtitle C Site Identification Form (Environmental Protection Agency (EPA) Form 8700-12)” to notify the EPA of participation. 

If an organization is an LQG of hazardous waste, notification may be done with the biennial or annual report. If the organization is an SQG of hazardous waste, submission of Form 8700-12 is required within 60 days of the state’s adoption of the rule. If that time period has already passed, notification should be submitted as soon as possible.

Steps environmental services managers may use to get started include:

  1. Determine if the facility is either an SQG or an LQG of total hazardous waste. If unsure of the quantity limits, refer to the EPA’s summary table. Count hazardous waste generated anywhere in the facility, including pharmacy, nursing, environmental services, lab, grounds and maintenance, and other areas.
  2. If it is determined that the facility is a very small quantity generator (VSQG) of hazardous waste, including hazardous waste pharmaceuticals, the facility may still register under Subpart P to receive the benefit but is not required to do so. If the facility does not, the state’s current hazardous waste generator rules for VSQGs will apply, and the facility must continue to document the hazardous waste pharmaceutical generation monthly going forward, including P-listed waste such as warfarin. VSQGs benefit from the empty package exclusion under the new rule, regardless of whether or not they register. So, warfarin and nicotine blister packs are no longer considered hazardous waste.
  3. Determine if the state requires a state-specific version or the federal Form 8700-12 Site Identification Form by checking the reference and following the state’s instructions. Determine if the state requires an electronic submission process through “RCRAInfo Industry Application” using my RCRAid.  
  4. The remaining instructions address only the federal form 8700-12 but provide enough information to assist with the completion of state forms also. A general review of the process can be accessed
  5. Access the actual 8700-12 form . It is extracted from a larger form that contains two other forms, the Biennial Report Form and the Part A Permit Application, which are not relevant to Subpart P and this process.
  6. Go to RCRA Subtitle C Reporting Instructions and Forms and carefully read the instructions on pages 1 through 4. The information through page 10 is background information, which is interesting to environmental services managers but not necessary if they have decided to file Form 8700-12. 
  7. Obtain or update an EPA ID number. If the facility already has an EPA ID number, update to indicate the facility will be managing hazardous waste pharmaceuticals under Subpart P. If the facility has never registered with the EPA, the facility will also be obtaining an EPA ID number in addition to registering under Subpart P. See pages 11 through 13 of Form 8700-12 instructions. Registration under Subpart P is not specifically called out in this discussion. If unsure if an EPA ID number is registered or not sure what it is, search for it here.
  8. Specific requirements for completing the form are listed on page 14 of the Form 8700-12 instructions. Complete in an initial electronic format or use black ink, indicate choices with an X as instructed and submit the final form with an original signature, not a photocopy. Enter the EPA ID number in the top left-hand corner of each page. If submitting for the first time, leave it blank.
  9. If the state requires submittal using myRCRAid, there are some training videos to assist in registering. One video is provided by the California Department of Toxic Substances Control. At the time of this publication, California has not yet adopted Subpart P, and that will be indicated in the video. A PowerPoint is also available from the Delaware Department of Natural Resources and Environmental Control. Delaware has adopted Subpart P. 

Completing the RCRA Subtitle C Site Identification Form

Once the instructions have been reviewed and the initial required information gathered for a “RCRA (Resource Conservation and Recovery Act) Subtitle C Site Identification Form (Environmental Protection Agency (EPA) Form 8700-12),” completing the form should take no longer than about 15 minutes. Environmental services (EVS) managers should note that the date of ownership is optional. They should also note that the legal name may be different from the operating name and should refer to the entity that owns the land upon which the site operates. The organization’s accounting department should be able to provide that information. 

These entries should assist in ensuring accurate responses:

No. 1: Reason for submittal. Check “Obtaining or updating an EPA ID number for an ongoing regulated activity that will continue for a period of time.”

No. 2: Site EPA ID number. The first two characters of the EPA identification number must be a valid state postal code. If this is the initial notification for this site, leave the EPA identification number blank. 

No. 3: Site name.

No. 4: Site location address. Do not use a P.O. Box number. This must be a physical address.

No. 5: Site mailing address. If it is the same as the physical address, check the “Same as location address” box. This entry may include a P.O. Box number.

No. 6: Site land type. Usually this will be private for a health care facility, but could be county, federal, tribal or other type. Pick the most descriptive (e.g., county rather than municipal).

No. 7: North American Industry Classification System codes. Provide the code that best fits the primary function in box A. Use the six-digit code if available. Use a five-digit code if necessary, but not a four-digit code. The office staff should have this information, or search for the code. See pages 523 to 541 for health care-related codes. These are very specific, so all relevant options should be reviewed. 

No. 8: Site contact information. Enter the primary site RCRA hazardous waste contact here. This is usually the facilities manager or EVS director. If there are other contact people involved, enter their information in item No. 18, including the person completing the form, if they are not the primary site contact.

No. 9: Legal owner and operator of the site. Indicate all owners and operators of this site. For example, if a realty company owns the land but a health care facility is operating a hospital, both entities should be listed with the appropriate contact information. The owner and operator information is listed accordingly. The date they became an owner, month, day and year, is optional information based on the guidance document. There may be multiple owners. All must be listed. The comments section may be used for this information and additional pages may be added, but the EPA ID number, if known, must be in the upper left-hand corner of each page. The operator is the person responsible for the overall operation of a RCRA site. Additional operators can be added to the comments page or additional pages attached with the EPA number in the upper left-hand corner. 

No. 10: Type of regulated waste activity (at the site). This section has multiple parts as follows: (A) Hazardous waste activities: 1. Generator of Hazardous Waste: Indicate if large quantity generator (LQG), small quantity generator or very small quantity generator (VSQG). Most health care facilities will respond “No” to the remainder of questions in this section; (B) Waste Codes for Federally Regulated Hazardous Wastes: List all nonpharmaceutical hazardous waste codes. A health care facility operating under Part 266 Subpart P is not required to list the waste codes for its hazardous waste pharmaceuticals. All other nationally defined waste codes are listed here. List them in the order given at this site; and (C) State-Regulated (Non-Federal) Hazardous Wastes: A number of states list additional pharmaceuticals as state-only hazardous wastes. Check with the state to determine if this is the case and if these must be listed on this form.

No. 11: Additional regulated waste activities. (A) Other Waste Activities: “No,” most health care facilities will not be involved in these activities; (B) Universal Waste Activities: “No,” while it is likely health care facilities will recycle batteries, lamps and other items, it is unlikely they will qualify as a large quantity handler of universal waste (accumulation of 5,000 kilograms or more); (C) Used Oil Activities: “No,” also unlikely for health care facilities to be involved; and (D) Pharmaceutical Activities: “Yes,” 1. Operating under 40 CFR 266 Subpart P for the management of hazardous waste pharmaceuticals. Mark only a. Healthcare facility, not b. Reverse distributor.

No. 12: Eligible academic entities with laboratories. “No,” not applicable.

No. 13: Episodic generation. “No,” not usually applicable to health facilities.

No. 14: LQG consolidation of VSQG hazardous waste. If operating under Subpart P, this option already exists for the management of hazardous waste pharmaceuticals. If other hazardous wastes are being consolidated under this provision of the Generator Improvements Rule, respond “Yes” and fill out the required addendum.

No. 15: Notification of LQG site closure for a central accumulation area or entire facility. “No,” not applicable unless the facility is closing.

No. 16: Notification of hazardous secondary material activity. “No,” not relevant to health care facilities.

No. 17: Electronic manifest broker. “No,” not applicable for health care facilities.

No. 18: Comments section for any additional information generated above requiring more space. Include the item and box letter, if applicable. Add the ID number to additional sheets.

No. 19: Certification. This certification must be signed and dated by the generator(s), owner(s), operator(s) or authorized representative(s) of the site. Anyone other than a recognized authority within an organization must be authorized by one of the officers of the organization by submitting their name in writing to the state director in an authorized state or the EPA regional director in nonauthorized states. This certification is a serious responsibility and should not be taken lightly.