Hazardous Waste Manifests

Course Description:

Any generator that offers hazardous wastes for transportation for off-site treatment, storage, or disposal must prepare a manifest using a U.S. Environmental Protection Agency, or EPA, Uniform Hazardous Waste Manifest (EPA Form 8700-22). Although the hazardous waste generator bears the responsibility for creating the manifest, transporters and receiving facilities also play a key role. Training is necessary to ensure compliance with this shipping paper that is the key to documenting the safe and compliant transport of hazardous waste. Those responsible for signing a manifest or for completing any part of this specialized shipping paper should receive training so that they understand and can competently perform their role. Regulations regarding hazardous waste manifests are found for hazardous waste generators at 40 Code of Federal Regulations, or CFR, 262 Subpart B; for transporters at 40 CFR 263 Subpart B; and for receiving facilities, including treatment, storage, and disposal facilities, or TSDFs, at 40 CFR 264/265 Subpart E. This training session will describe how to properly complete a manifest, help you know what additional documents may need to be attached to the manifest, and explain how parts of the manifest are distributed.

Why “Hazardous Waste Manifests” Matters:

• The Uniform Hazardous Waste Manifest (Form 8700-22) is the shipping document that travels with hazardous waste from the point of generation, through transportation, to the final treatment, storage, or disposal facility (TSDF).
• Each party in the chain of shipping, including the generator, signs and keeps a designated part of the waste manifest.
• It is essential to fill out all the numbered sections of the manifest and do so correctly.Filling out a continuation sheet, Form 8700-22A, is required if more than two transporters are to be used to transport the waste or if more space is required for the DOT description of hazardous materials and any related information.Many other documents may be attached to a Hazardous Waste Manifest, including land disposal restriction forms, hazardous waste determinations, copies of analytical results, such as TCLP (Toxic Characteristics Leaching Procedure) tests, and emergency response information.
• It is vital to know what to do if this system for transparent tracking breaks down, and how to fill out exception reports.

Key Points:

• Hazardous Waste Manifests are straightforward documents that are essential pieces of the compliance puzzle for a hazardous waste generator, transporter, or receiving facility.
• It is important that the waste manifest be completed in full and that all appropriate items are completed correctly.
• Manifests have designated parts for generators, transporters, and receiving facilities. It is essential that all parties involved retain their copies for at least 3 years.
• And copies are also sent to state environmental agencies in both the generator and the destination states. This allows state agencies to track where wastes go and how long they take to get there.