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Suppliers Asking for RCRA ID Numbers

It’s that time of year, ISRI members. If you receive a call or an email from a supplier requesting your RCRA (Resource Conservation and Recovery Act) ID number (aka EPA ID number), there is a real reason for it.

These requests tend to be more frequent during June, especially late June, because of the July 1 deadline for Toxic Release Inventory (TRI) reporting. Your suppliers may need to submit TRI reports.

The TRI regulations generally require facilities in certain industries (but not the recycling industry under SIC Code 5093 or 5015) to complete and submit Form R for each "chemical" manufactured or processed above a certain annual quantity threshold in those facilities. The TRI chemicals include metals: notably (but not only)—aluminum (fume or dust), antimony, beryllium, cadmium, chromium, cobalt, copper, lead, manganese, mercury, nickel, silver, vanadium (except when alloyed), and zinc (fume or dust). Form R asks for the RCRA ID number of any off-site facility that receives TRI chemicals from a reporting facility. It does not matter whether the chemicals are regulated as waste or not. Reporting facilities must submit by July 1 their Form(s) R for previous calendar year activities.

For better or worse, EPA opted to use TRI (and Form R) to allow reporting facilities to indicate which of their TRI chemicals are recycled off-site. This has the unfortunate consequence of equating recycling with a release of toxic chemicals. Because recyclers are not required to have RCRA ID numbers, a request for a RCRA ID number may seem troubling; however, the correct response for a receiving facility with no RCRA ID number (e.g., a recycler) is "NA" (for "Not Applicable") (see here). At the same time, a recycler may have a RCRA ID number because of certain RCRA-regulated activities that it conducts, so that number should be provided to a requesting supplier for TRI purposes.

If you have questions about whether you have a RCRA ID number, please contact Chief Scientist and Director of Environmental Management David Wagger at (202) 662-8533.

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