Our advice
Define key terms: ICPE and operator, activity and facility

To determine whether your facility is classified under ICPE regulations, you must conduct—or have conducted—a comprehensive inventory of all activities and products used at your site.

If you are not careful, you risk overlooking an activity or material that you will not be legally permitted to use. You also risk misclassifying your facility. In either case, you will find yourself in an illegal situation that could result in penalties from the authorities and legal sanctions in the event of a dispute.