Why Do I Have to Complete the Subpart P 8700 Form for Waste Generators?

According to the Resource Conservation and Recovery Act (RCRA), any person in the US who transports, recycles, or generates regulated waste or owns or operates a facility for these uses must notify the Environmental Protection Agency (EPA). 

This includes the location and a general description of the wastes that are handled there. The EPA strives to ensure that regulated waste is dealt with in a way that protects public health and the environment.

Waste generators are individuals who produce and manage their waste containers and waste storage areas. The RCRA has a specific approach to managing and handling the large volumes of waste created each year. 

The Subtitle C section (Hazardous Waste) of the RCRA regulations gives the EPA authority to manage hazardous waste from “cradle-to-grave.” This means the generation, transportation, storage, and disposal of waste should be managed according to their designated guidelines.

Continue reading for more information on this, more specifically how subpart P affects your business, why it matters, and how environmental consultants can help you along the way.

What Is the Subpart P 8700 Form? 

Subpart P references the management of solid waste pharmaceuticals that are hazardous. Again, this is mandatory for healthcare facilities that are:

  • Small Quantity Generators (SQG’s) – Facilities generate more than 100 kilograms but less than 1,000 kilograms of hazardous waste per month. 
  • Large Quantity Generators (LQG’s) – These facilities generate more than 1,000 kilograms of hazardous waste a month or more than 1kg a month of acutely hazardous waste. 
  • Reverse Distributors (RD’s) – Any pharmaceutical manufacturer who processes pharmaceuticals for the facilitation/verification of manufacturer credit is, under the rule, considered a reverse distributor. 

However, Subpart P is optional for tiny quantity generators (VSQG’s) except in some circumstances (for example, the hazardous pharmaceutical waste sewer ban).

However, even VSQG’s are recommended to enforce Subpart P to track their waste efficiently. 

Subpart P was implemented in 2019. It outlaws the disposal of pharmaceutical waste in unregulated ways (e.g., via the workplace sink). The adoption of Subpart P varies by state or authorization status.

Under subpart p regulations, hazardous pharmaceutical waste will no longer count towards waste generator status. Therefore, if your state adopts subpart P and you have to calculate whether your facility should register under subpart P, your facility may drop from LQC to SQC. You must be operating under subpart P for pharmaceutical waste not to count toward your generator status.

Put simply, this means that pharmaceutical waste will not impact whether a facility is considered a very small, small, or large quantity generator. 

Determining Waste Generator Status

Not sure what your waste generator status is? You’ll need to do the following:

Determine if you’re an SQG or an LQG: To do this, you should refer to the EPA’s summary table here. Determine state guidelines: You’ll need to figure out if your state requires you to fill out their state-specific version of the 8700-12 site identification form. Please refer to the EPA website for this information.

Obtain or update an EPA number:  If you’ve never registered with the EPA, you’ll need to apply for an EPA number in addition to registering under the subpart. 

Suppose you already have an EPA ID number. In that case, you’ll be updating it to indicate that you are managing hazardous waste pharmaceuticals (as listed under subpart p).

Unfortunately, for many states, Covid-19 has delayed the adoption of subpart P. If there’s no state legislation, the current state adoption deadline is 7/1/2021. If state legislation is required, the adoption deadline is 7/1/2022.

The following states have officially adopted subpart P:

  • Alabama
  • Alaska
  • Arizona
  • Colorado
  • Denver
  • Florida
  • Georgia
  • Illinois
  • Indiana
  • Iowa
  • Kentucky
  • New Jersey
  • North Carolina
  • Ohio
  • Oklahoma
  • Pennsylvania
  • South Carolina
  • South Dakota
  • Utah
  • Virginia
  • Washington
  • West Virginia
  • Wisconsin

But, more states are expected to be added to this list, so watch this space!

Generators and EPA Guidelines

According to EPA guidelines, a waste generator should receive an identification number before treating, storing, disposing, or transporting (or requesting transport for) hazardous waste.

These numbers can be obtained by filling out forms 8700-12 from the FDA. 

Each hazardous waste generator has its own summary of requirements. As some states have more stringent requirements with the federal government, you should familiarise yourself with them thoroughly and how they can specifically affect your site development

How Do I Fill Out Subpart P?

Please refer to the EPA website to find the subpart P form and for more in-depth guidance on how to complete it. The EPA form is split into 22 sections. These sections include specifying your reasons for submission, site EPA ID number, name and location address, details of regulated waste activities, and more.

Important points to remember: 

If your subpart P form is incomplete in any way, it may be rejected. You could receive a phone call, email, or the document will be returned to you. So, ensure you fill in all the appropriate areas and refer to the full EPA guidelines before filling out this form.

Also, if you’re applying for a new EPA number, this will be sent to you via email after your subpart p form has been processed. The process for issuing a permanent EPA ID number usually takes between 7-10 days. 

Ensuring Safety and Good Working Practice – Subpart P and Beyond

Do you need help improving the safety and security of your workplace environment? Are you confused about Subpart P or other environmental issues and seeking cost-effective and practical solutions to workplace and environmental problems?

As licensed and accredited environmental professionals, Midwest Environmental Consulting Services offers advice and support on following federal and state regulations and ensuring safe work practices. Give us a call today, we create safe work environments for clients, staff, and their partners.

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