By Dawn Hargrove-Avery, Executive Director & Chief AI Officer, National Cleaners Association

The drums are full. The pickup is booked. Then the waste hauler asks one question:

"What's your EPA ID number?"

For a business that has operated for years, the answer may be on an old hazardous waste manifest. For a new owner, that question can bring the entire pickup to a halt.

The number may still be registered under the previous operator's name. The drums in the back may have been left behind by that operator. And nobody necessarily explains the environmental responsibilities that come with taking over a dry-cleaning business.

Understanding how hazardous waste is identified, stored, transported and disposed of is an important part of operating a professional garment-care business.

This guide explains what an EPA ID is, when a cleaner needs one, which permits apply, how hazardous waste should be removed and what to do when taking over a location with waste already on site.

Before Your Next Waste Pickup: Six Questions to Ask

Before scheduling a hazardous waste pickup, make sure you can answer these questions:

1. Does your location have an EPA hazardous waste identification number, and do you know whether one is required?

2. What is your hazardous waste generator category for the current calendar month?

3. How much hazardous waste is currently stored at your facility?

4. Is your waste transporter authorized to transport your specific waste?

5. Do you have the required manifests or other documentation from previous pickups?

6. If you recently purchased or leased the business, have you reviewed the previous operator's environmental records?

If you cannot answer one of these questions, that is where you should begin.

What Counts as Hazardous Waste in a Dry-Cleaning Business?

Not all dry-cleaning waste is regulated in the same way. The answer depends on the solvent, the material being discarded and whether the waste meets federal or state hazardous waste criteria.

Facilities using perchloroethylene, commonly called perc or PCE, typically generate hazardous waste that may include:

• Spent perc solvent.

• Still bottoms and distillation residues.

• Spent cartridge filters.

• Contaminated filter powder and sludge.

• Certain contaminated separator-water wastes.

• Other materials containing regulated solvent residues.

Spent perc used in dry cleaning is generally classified as F002 hazardous waste. Some waste may also carry the D039 code when it exhibits the toxicity characteristic for tetrachloroethylene.

Unused commercial chemical products containing perc may be subject to different hazardous waste classifications, including U210 when the applicable listing criteria are met.

The correct waste codes must be determined for each waste stream. A cleaner should not assume that every material containing solvent automatically receives the same classification.

Other dry-cleaning solvents and spotting chemicals may also create hazardous waste, depending on their ingredients and characteristics.

A cleaner using an alternative solvent should not assume that its waste is automatically nonhazardous.

The rule is simple: identify the waste before deciding how it can be handled or disposed of.

Hazardous solvent wastes should never be poured down a drain, placed in ordinary trash or released onto the ground.

Source: EPA, Typical Wastes Generated by Industry Sectors

What Is an EPA ID Number?

An EPA hazardous waste identification number is a 12-character identification number assigned under the Resource Conservation and Recovery Act (RCRA).

It identifies a physical site involved in regulated hazardous waste activities.

The number is used in regulatory records and, when required, on hazardous waste manifests that document the movement of waste from the generator to an authorized receiving facility.

There are two important facts every cleaner should understand.

First, the EPA ID is associated with the physical location, not permanently with a particular business owner.

If a dry cleaner previously operated at the same address, an EPA ID may already exist. The new owner or operator generally updates that site's information rather than obtaining a different number.

Second, an EPA ID is not a hazardous waste disposal permit.

Having an EPA ID does not authorize a cleaner to transport, treat or dispose of hazardous waste without complying with applicable requirements.

It identifies the facility for regulatory tracking purposes.

Does Every Dry Cleaner Need an EPA ID?

Not necessarily.

Federal hazardous waste regulations establish three generator categories, primarily based on the amount of hazardous waste generated during each calendar month.

Generator category	Non-acute hazardous waste generated monthly
Very Small Quantity Generator (VSQG)	100 kg (about 220 lbs.) or less
Small Quantity Generator (SQG)	More than 100 kg but less than 1,000 kg
Large Quantity Generator (LQG)	1,000 kg (about 2,200 lbs.) or more

Small and large quantity generators must obtain an EPA ID.

Very small quantity generators generally do not need one under the federal rules, although other requirements or shipping arrangements may make an ID necessary or useful.

New York regulations commonly refer to very small quantity generators as Conditionally Exempt Small Quantity Generators (CESQGs).

There is another important qualification.

The thresholds above apply to ordinary, non-acute hazardous waste. Acute hazardous waste has much lower thresholds. Generating more than one kilogram of acute hazardous waste during a calendar month can place a facility in the large quantity generator category. Special rules also apply to residues from certain acute hazardous waste spills.

Your generator category must account for all hazardous waste streams that the regulations require you to count.

A cleaner should not determine its category based only on the number of drums collected by a hauler.

Source: EPA, Categories of Hazardous Waste Generators

How Much Hazardous Waste Can You Keep on Site?

The amount generated each month and the amount stored at the facility are two different measurements.

Both matter.

Under the general federal framework:

• Very small quantity generators may accumulate no more than 1,000 kg (approximately 2,200 lbs.) of non-acute hazardous waste on site at one time while remaining within the VSQG accumulation exemption.

• Small quantity generators may generally accumulate no more than 6,000 kg (approximately 13,200 lbs.) and must follow applicable accumulation time limits, generally 180 days or 270 days for qualifying longer-distance shipments.

• Large quantity generators have more extensive accumulation, labeling, emergency preparedness and operational requirements, including a general 90-day accumulation limit.

Additional restrictions apply to acute hazardous waste, and state-specific rules must also be considered.

This is particularly important when a business has drums that have been sitting in storage for months or years.

A facility that generates very little waste each month can still become subject to more demanding requirements if its accumulated waste exceeds the applicable limit.

Old drums do not become exempt simply because they were left by a previous owner.

A cleaner should maintain an accurate inventory and schedule authorized waste removal before accumulation limits are exceeded.

How to Find or Obtain an EPA ID Number

For a New York dry-cleaning business, the process begins with determining whether a number already exists.

Step 1: Search for an existing EPA ID

Start by reviewing:

• Previous hazardous waste manifests.

• Waste removal invoices and shipping documents.

• Environmental inspection records.

• Records provided by the former business owner.

• Correspondence with EPA or the New York State Department of Environmental Conservation (DEC).

You can also search EPA's public RCRA database by address, facility name or identification number.

Search EPA's Hazardous Waste Information Platform

Use the physical facility address rather than relying only on the current business name.

Step 2: Confirm the site's information

Finding a number does not automatically mean the information is current.

Check whether the site record identifies the correct location, business operator and hazardous waste activities.

If a previous owner is still listed, the current operator should arrange to update the record.

An inactive or deactivated identification number may also need to be updated or reactivated.

Step 3: Submit EPA Form 8700-12

If the facility needs a new EPA ID or must update an existing record, the appropriate filing is generally EPA Form 8700-12, the RCRA Site Identification Form.

For New York facilities, EPA Region 2 accepts the form electronically through myRCRAid or by mail.

The filing requires information about the facility, including its physical address, site contacts, owner and operator information, and applicable hazardous waste activities.

EPA Region 2: Hazardous Waste Site Identification

Step 4: Wait for confirmation and coordinate the pickup

Electronic submissions must be reviewed and approved by the regulator before changes are entered into the official record.

Confirm the applicable identification information with your hauler and make sure the waste shipping documents are correct.

Do not assume that submitting a form immediately resolves every regulatory or shipping requirement.

What if there is an emergency?

EPA Region 2 provides a separate procedure for emergency hazardous waste identification numbers involving urgent situations such as spills, accidents or abandoned waste that poses an immediate concern.

The Region 2 emergency EPA ID contact number is 212-637-4106.

This emergency process is not a substitute for ordinary site registration or routine ownership updates.

Who Needs Which Permit to Remove Hazardous Waste?

One of the most common misunderstandings is that the dry cleaner must obtain a hazardous waste disposal permit simply to have waste removed.

That is generally not the case.

A cleaner operating as a hazardous waste generator must comply with the applicable generator requirements. The transporter and receiving facility have separate authorization requirements.

The dry cleaner: Hazardous waste generator

The business is responsible for identifying its waste, determining its generator category and meeting applicable accumulation, container management, labeling, recordkeeping and shipping requirements.

The cleaner also needs to verify that its waste management arrangements are appropriate.

The waste hauler: Authorized transporter

In New York, transportation of hazardous waste generally requires a valid Part 364 Waste Transporter Permit.

Before arranging pickup, ask the transporter to provide its permit.

Confirm that the authorization covers the type of waste being transported and the intended receiving facility.

A company may be authorized to transport one type of waste without being approved to transport every regulated material.

Source: NYSDEC, Waste Transporters

The receiving facility: Authorized treatment or disposal facility

Hazardous waste must be delivered to a facility legally authorized to manage that waste.

Depending on the operation, the receiving facility may require a hazardous waste treatment, storage or disposal permit under New York's Part 373 regulations or other applicable authorization.

Ask your hauler where the waste will be delivered and confirm that the facility can accept the material.

The manifest: Documenting the shipment

For shipments requiring a hazardous waste manifest, the Uniform Hazardous Waste Manifest tracks the waste from the generator through transportation to the designated receiving facility.

The manifest identifies the participants, waste and shipment information, and is signed at the appropriate stages.

EPA's e-Manifest system allows regulated waste shipments to be tracked through paper, hybrid and fully electronic manifest processes.

However, not every hazardous waste shipment requires a manifest.

In New York, qualifying CESQGs are generally exempt from the standard hazardous waste manifest requirement. They must still ensure their waste is handled through an authorized waste management arrangement and maintain appropriate documentation.

A CESQG may also choose to use a manifest, and transporters or receiving facilities may require additional records.

A disposal invoice is useful, but it should not be confused with proof that every applicable hazardous waste obligation has been satisfied.

For manifested shipments, verify the completed manifest and investigate missing confirmation as required.

For non-manifested shipments, retain the available pickup receipts and receiving documentation.

Source: NYSDEC, Hazardous Waste Manifest System

What If You Buy a Dry Cleaner and Inherit Hazardous Waste?

Purchasing or leasing an existing dry-cleaning location can create environmental questions that are easy to overlook.

A new owner may discover drums of still bottoms, old filters, unused solvent or unidentified chemicals in a storage area.

The first step is not to arrange ordinary trash removal or attempt to empty the containers.

Do not open, mix, drain or move unidentified waste without an appropriate safety assessment and qualified assistance.

Document the visible condition of the containers from a safe location. If a container appears to be leaking, damaged or creating an immediate hazard, keep people away and contact appropriate emergency responders or qualified environmental personnel.

Ask the previous owner or landlord for:

• Past hazardous waste manifests and pickup records.

• The site's EPA ID information.

• Environmental inspection reports.

• Records of stored chemicals and waste.

• Information about previous equipment and solvents.

• Any available site assessments or contamination investigations.

A qualified environmental professional can help determine what the materials are and how they must be managed.

This is especially important when contamination of floors, drains, soil or groundwater is suspected.

Updating an EPA ID record does not automatically determine who is financially or legally responsible for waste left by a previous operator.

Responsibility can depend on environmental law, ownership history, lease provisions, purchase agreements and the circumstances of the waste.

Prospective purchasers should consider an appropriate environmental due-diligence review before completing a transaction.

The best time to investigate abandoned waste is before signing the purchase or lease agreement, not after the cleanup bill arrives.

Retiring a Perc Dry-Cleaning Machine

When a perc machine is permanently removed from service in New York, the shutdown and disposal process requires particular attention.

Under New York's Part 232 program, a Notice of Dry Cleaning Equipment Shutdown must be submitted to DEC no later than 30 days after the machine stops operating.

DEC specifies submission by certified mail or another method providing the required return receipt.

The machine must also be properly managed before disposal or recycling.

New York provides different disposal pathways.

A machine can potentially be cleaned to applicable hazardous waste decontamination standards before disposal as nonhazardous waste or scrap metal.

Under the conditions specified by DEC, cleaning completed within 90 days after shutdown may be performed on site without obtaining a Part 373 hazardous waste treatment permit.

After that period, the applicable cleaning must be performed at an appropriately permitted facility.

Another option may be to send an uncleaned machine to a properly authorized hazardous waste facility or scrap metal reclaimer equipped and authorized to manage the contamination.

Drained perc, contaminated liquids and other hazardous residues must still be properly characterized and managed.

A retired perc machine should never be treated as ordinary scrap simply because it is no longer operating.

Before disconnecting or moving equipment, consult DEC guidance and a qualified contractor.

Source: NYSDEC, Dry Cleaner Regulation

Other New York Requirements Cleaners Should Know

An EPA ID is only one part of the regulatory picture.

Air facility registration

Most New York dry-cleaning facilities require an Air Facility Registration.

Some larger operations may require a State Facility Permit or Title V permit instead.

Facilities must obtain the appropriate authorizations before beginning operations and before certain equipment installations or solvent changes.

An EPA ID does not replace an air registration or permit.

Ownership changes

When a dry-cleaning facility changes ownership, DEC requires an updated Air Facility Registration application within 30 days of the ownership change.

New owners must also ensure that all required authorizations and certifications are in place before operating.

Updating the air registration is separate from updating the EPA hazardous waste identification record.

Perc operator certification

New York's Part 232 program requires applicable owners, managers and operators of perc dry-cleaning equipment to maintain the required DEC-approved training and certification.

The certification program includes 16 hours of approved instruction and an examination, with renewal required every five years.

A new operator should not assume that enrollment in a future course is sufficient authorization to begin operating a perc machine before the required certification has been obtained.

Perc equipment in residential buildings

New York has prohibited perc dry-cleaning equipment in buildings containing residential occupancy since December 21, 2020.

A business considering a new location or taking over an existing shop should verify that the proposed equipment and building use are permitted.

Source: NYSDEC, Dry Cleaner Regulation

What About the Federal Perc Phaseout?

Federal requirements for perchloroethylene are also changing.

In December 2024, EPA finalized a rule under the Toxic Substances Control Act establishing phased restrictions on PCE, including its use in dry cleaning.

The published rule established these important dry-cleaning milestones:

Date	Requirement established in the 2024 rule
June 16, 2025	Prohibition on using PCE in newly acquired dry-cleaning machines
December 20, 2027	Prohibition on PCE dry cleaning and related spot cleaning in third-generation machines
December 19, 2034	Final prohibition on PCE use for dry cleaning and related spot cleaning

Important regulatory update: EPA began reconsidering the 2024 PCE rule in 2025 and announced further rulemaking activity and compliance-date changes during 2026.

Some workplace-protection compliance dates have been extended, but those changes should not be confused with a blanket cancellation of the dry-cleaning phaseout.

The published restrictions remain the relevant starting point unless and until modified by an effective regulatory action.

Dry cleaners should verify the latest EPA requirements before buying equipment, making capital investments or planning a solvent transition.

Source: EPA, Risk Management for Perchloroethylene

How NCA Helps Members Navigate Hazardous Waste Requirements

Environmental questions rarely arrive at a convenient time.

Sometimes a waste hauler is waiting for an EPA ID. Sometimes a cleaner has just purchased a business and discovered old drums in the storage area. Other times, an operator is trying to understand whether a registration, training requirement or disposal procedure applies.

These are situations where the National Cleaners Association can help members understand the process and identify the next appropriate step.

NCA can help members:

• Understand the difference between an EPA ID, a hazardous waste manifest and a waste transporter permit.

• Determine what information is needed to evaluate their generator category.

• Locate EPA and DEC forms and regulatory guidance.

• Identify questions to ask waste haulers and environmental contractors.

• Understand applicable New York Part 232 requirements.

• Prepare questions and documentation for regulatory agencies.

• Recognize when specialized environmental or legal assistance is necessary.

NCA does not replace the regulatory agencies or the professionals responsible for determining waste classifications and performing authorized hazardous waste work.

Our role is to help cleaners understand what applies, what documentation matters and where to obtain the appropriate assistance.

For a small independent operator, that guidance can make the difference between an organized response and an expensive mistake.

Your Action for This Week

Start a hazardous waste compliance folder for your business.

Include:

• Your EPA ID information, if applicable.

• Your generator category calculations and waste inventory.

• Your air facility registration or permit.

• Required operator certifications.

• Your waste transporter's authorization.

• Recent hazardous waste manifests or pickup receipts.

• Completed receiving-facility confirmations where applicable.

• Relevant inspection reports and environmental correspondence.

Make sure someone in the business knows where these records are kept and who is responsible for maintaining them.

Then review your next scheduled waste pickup.

Confirm the waste being collected, the authorized transporter, the receiving facility and the documentation needed.

The objective is not to turn every dry cleaner into a hazardous waste specialist.

It is to ensure that every owner understands enough to recognize a problem, ask the right questions and bring in the right expertise.

One issue. One problem. One step at a time.

Sources and Further Reading

1. U.S. EPA: Categories of Hazardous Waste Generators

2. U.S. EPA: Typical Wastes Generated by Industry Sectors

3. U.S. EPA Region 2: Hazardous Waste Site Identification

4. EPA Hazardous Waste Information Platform

5. NYSDEC: Waste Transporters

6. NYSDEC: Hazardous Waste Manifest System

7. NYSDEC: Dry Cleaner Regulation

8. U.S. EPA: Risk Management for Perchloroethylene

Regulatory note: This article provides general educational information based on federal and New York requirements reviewed November 3, 2026. It is not legal advice or a substitute for regulatory guidance, hazardous waste determinations or professional environmental services. Requirements vary by state, facility, solvent, waste classification and generator category. Verify applicable requirements with the appropriate regulatory agency before acting.