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Understanding the Role of Hazardous Waste Generators

Updated: Jun 14

In the realm of hazardous waste management, understanding the role of a generator is crucial. According to the California Code of Regulations Title 22 (22 CCR) section 66260.10, a Generator is defined as “any person, by site, whose act or process produces hazardous waste identified or listed in Chapter 11 of the hazardous waste regulations or whose act first causes a hazardous waste to become subject to regulation.”


While in California, generators typically refer to businesses or government agencies, it’s essential to note that in certain scenarios, households can also fall under this classification.

What exactly constitutes hazardous waste? Hazardous waste encompasses materials possessing properties that render them potentially harmful to human health or the environment. These substances come in various forms – liquids, solids, or contained gases – and can stem from manufacturing by-products, used materials, or even unused commercial products like cleaning fluids (solvents), asbestos, pesticides, or household cleaners. Whether a waste is deemed hazardous often hinges on its classification as a federal or state-listed waste or if it exhibits characteristics of hazardous waste (ignitable, corrosive, reactive, or toxic).


Generators shoulder the responsibility of accurately characterizing all their hazardous waste. The process for such determination is outlined in 22 CCR section 66262.11. Once a generator confirms that their waste meets the hazardous waste definition, the applicable requirements hinge on the nature of the waste and the volume generated.

For a comprehensive understanding of generator requirements and how pertinent laws and regulations apply to your situation, it’s imperative to discern whether you fall under the category of a business or a household. This distinction sets the stage for navigating the regulatory landscape effectively and ensuring compliance with hazardous waste management protocols.


At Reliance Construction, we proudly undertake the role of your representative to facilitate the acquisition of a customized EPA ID# tailored to your property and project. Additionally, we meticulously manage all aspects of hazardous waste disposal procedures in accordance with mandated laws and protocols. Upon delivery of your hazardous waste to a designated landfill, you will receive comprehensive documentation as evidence of proper disposal, ensuring compliance and providing peace of mind for your future records.


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Temporary State ID numbers


Typically, temporary State ID numbers are issued for one-time or short-term occurrences of hazardous waste removal, such as the removal of asbestos waste, cleanup of hazardous waste spills, or tank removal. Additional information about ID numbers is available on our website at https://dtsc.ca.gov/.


The Department of Toxic Substances Control (DTSC) notifies the California Department of Tax and Fee Administration (CDTFA) when an ID number has been issued. The CDTFA administers four hazardous waste fee programs in cooperation with the DTSC, pursuant to the requirements of the California Hazardous Substances Tax Law. One of the hazardous waste fee programs is the Generation and Handling (G&H) Fee. The G&H Fee applies to every person or business that generates five or more tons of hazardous waste at a site in California within a calendar year or portion of the calendar year. This includes most recycled waste, treated wood waste, imported non-RCRA (Resource Conservation Recovery Act) waste, and waste sent outside California for disposal. The per ton fee is determined by the total tonnage of waste generated per site. The fee also applies to facility operators that generate five or more tons of hazardous waste who pay the Facility Fee. (HSC section 25205.5.). If the fee applies to you, you are required to register for a CDTFA G&H Fee account number at cdtfa.ca.gov. You may contact CDTFA at (800) 400-7115.


Using a hazardous waste hauler or contractor will not relieve you of the liability for the state fees that result from the generation, recycling and/or disposal of your hazardous waste. Per the Hazardous Substances Tax Regulation 3000 (b) (1) (G): "Generator" does not include an entity such as an environmental clean-up company or an emergency response contractor, when that entity, pursuant to contract, cleans up a release of hazardous waste for another person, unless the entity is identified on a hazardous waste manifest as the generator as described in subdivision (b)(1)(A).


If you have any questions about the temporary State ID number, contact DTSC's Business Operations Unit for ID number assistance at (800) 618-6942. Our telephone hours are Monday through Friday from 9:00 AM to 3:00 PM Pacific Time.

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