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Are You Correctly Using the Hazardous Waste Manifest at Each Waste Pickup?

Kevin Webber - Oct 16, 2018 3:35:30 PM

Man-Filling-Out-Hazardous-Waste-Manifest-FormThe Environmental Protection Agency’s hazardous waste manifest system was created to track hazardous waste from the time it leaves the facility where it was generated, until it reaches the off-site facility for storage, treatment, or disposal. The Uniform Hazardous Waste Manifest is the form that is the key component of the system, and it helps ensure accountability in the transportation and disposal process.

The manifest has information on the type and quantity of the waste that will be transported and instructions for handling it. Each party who handles the waste must sign the manifest and keep a copy for themselves. After the waste has reached its final destination, the receiving facility confirms that it has been received and properly handled by returning a signed copy of the manifest to the generator. Only then can the generator be assured that the waste was properly disposed.

Let’s look at a few common questions about the manifest system to help ensure that you use it correctly.

Are There State Requirements for Manifests?

Some states have additional requirements such as state-specific waste codes for the hazardous waste manifest. EPA provides a list of hazardous waste manifest programs in state environmental agencies to help you follow the regulations in your state. (A contact name and phone number is provided for states that have not completed a manifest web page.)

Also, as a hazardous waste generator, it is your responsibility to determine whether your state or the consignment state for a shipment, if your waste will travel out of state, regulates any additional wastes as hazardous wastes beyond those regulated federally. If so, they would be regulated under the consignment state’s authorized program.

Important to note: You must also determine whether the consignment state or generator state requires you to submit any copies of the manifest.

Who Can Print the Manifests?

Did you realize that the source printing the manifests has to receive approval from the Environmental Protection Agency (EPA)? EPA Manifest Registry approves printing and distribution of the forms, and you may apply to print the manifests as a hazardous waste generator. Other registered sources may include a state agency, a commercial printer, your hazardous waste transporter or Treatment, Storage, Disposal Facility (TSDF) as well as any other preparer such as a hazardous waste broker who either prepares or arranges shipments of hazardous waste for transportation.

Important to note: Make sure that your approved registrant has included your manifest tracking number (MTN) in Item 4 of your manifest form.

How Many Copies Do You Need?

Once the information is correctly filled out on the manifest, you must determine how many copies you will need to provide. You will at least need copies for the following:

  • The Department (if required)
  • The generator
  • Each transporter
  • The owner or operator of the designated facility
Important to note: You will need one copy each for their records and another copy that is returned to you, the generator.

How Do You Certify the Manifest?

As the hazardous waste generator, you or your designed manifest signer must sign the manifest certification by hand. Stamps are not allowed. You must also obtain a handwritten signature from the initial transporter and include the date that the waste was accepted. One copy is retained for your records and the transporter receives the remaining copies of the manifest.

Important to note: You are also required to provide a waste minimization certification, as outlined on the uniform hazardous waste manifest. Basically, if you are a small quantity generator (SQG) you must attest to having made a good faith effort to minimize your waste generation and use the best waste management method available. Large quantity generators (LQGs) must have an actual program in place to reduce the volume and toxicity of the hazardous waste they generate.

How Long Do You Keep Copies?

You are required to keep a copy of each manifest that you or your representative signs for three years or until you receive a signed copy from the designated facility that received your waste. That signed copy must be kept as a record for at least three years from the date that your waste was accepted by the initial transporter. (Some facilities keep copies as long as they are in business, as a best practice.)

Important to note: If, as a small quantity generator, you do not receive a signed copy from the designated TSDF within 60 days of shipment, you must submit a legible copy of the manifest to your state or EPA regional office. This indicates a signed copy was not received from the facility operator.

What About Electronic Manifests?

EPA launched the e-Manifest system on June 30, 2018 to electronically track hazardous waste shipments. The goal is to transition to an electronic system for cost savings and increased efficiencies. An electronic manifest may be used to track hazardous waste shipments only if you know at the time the manifest is originated that all of the waste handlers who are named on the manifest participate in the electronic manifest system.

Important to note: Generators who originate an electronic manifest must also provide one printed copy of it to the initial transporter. EPA recently granted extra time for receiving facilities to submit paper manifests during the initial months after the system launch and additional functionality will deploy throughout the fall of 2018.

The Uniform Hazardous Waste Manifest is designed to track your hazardous waste from the time it leaves your facility, until it reaches the off-site waste management facility that will store, treat, or dispose of it. Proper use of the form is key to managing the transportation and disposal of hazardous waste. Your waste management provider should be able to answer any questions you have about the manifest system. 

Topics: Hazardous Waste

Kevin Webber

Kevin Webber

Kevin Webber is a partner at TriHaz Solutions and actively involved in the day-to-day business from a strategic and operational standpoint. He has a successful background in business/investment management and entrepreneurship, including recognition by Inc. Magazine’s 5000 list of fastest-growing private companies.

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