The NEW Hazardous Waste Manifest

1
The NEW Hazardous Waste Manifest
2
Goals

• Upon completion of this course you will have an
• understanding of the following
• What a hazardous waste manifest is.
• When a hazardous waste manifest is required for
  transporting waste.
• When the new manifest rules go into effect
• Recognize the new Haz-Waste manifest
• Know the different sections of the manifest, the
  required information, and party responsible for
  completing each section.
• Proper load rejection steps
• How and where to obtain the new manifest

3
What is a Hazardous Waste Manifest?

• All loads of DOT
• Hazardous Materials
• require a shipping paper.
• A Hazardous Waste
• Manifest is a designated
• form of shipping paper
• required by the US EPA
• for transportation of
• Hazardous Waste.

4
When is a Manifest Required?

• All loads of Hazardous
• Waste and Texas Industrial Class 1 Waste must be
  accompanied by
• a completed Hazardous
• Waste Manifest when
• transported for disposal .

5
BackgroundEPAs Proposal to Improve the Uniform
Manifest

• USEPA proposed regulations published May 22, 2001
  included 3 major revisions to the manifest
  system.
• Standardize the content and appearance of the
  manifest form
• Define manifest tracking procedures for rejecting
  wastes and container residues
• Enable waste handlers to manifest electronically
• The intent was to improve the effectiveness of
  the manifest and reduce the paperwork burden on
  users.

6
Final Rule

• Published March 4, 2005
• Effective for all states on September 5, 2006
• Electronic manifest was not adopted in this rule.
  
• Requires consistency in the content and use of
  shipping papers
• Manifest is based on both RCRA and DOT
  requirements.

7
Manifest Revisions

• Removed Manifest Document Number
• Removed Transporter Phone numbers
• Added information for International Shipments
• Revised Definition of Bulk container to match DOT
  definition
• Changed from gt110 gallons to gt119 gallons
• Require weights to be listed in whole numbers
• Use appropriate unit to provide accurate volumes

8

• Generator EPA or State ID
• Page Number
• Emergency Response number (if applicable to
  entire load)
• Manifest Tracking Number (Pre-printed)
• Generators mailing address AND site address if
  different.

9

• Transporter 1 name and EPA ID (Phone
  requirement removed for transporters)
• Transporter 2 name and EPA ID (Not required
  unless a change in custody occurs between
  transportation companies)
• Designated Facility Name, Address, Phone and EPA
  ID

10

• 9a. HM must be identified (with and X)
• 9b. US DOT Description Emergency response if
  different per line item must be place after
  shipping description.
• 10. Number and type of containers. See manifest
  instructions for acceptable container types.
• 11. Total Quantity Use of decimals not allowed.
  Must report quantities of waste, NOT container
  sizes.
• 12. Unit See manifest instructions for options.
• 13. Waste Codes EPA and State Codes

11
Waste Code Instructions

• If the state waste code differs from the EPA
  waste code(s) it must be placed in item 13.
• Waste codes most representative of the waste
• No Waste code hierarchy
• ONLY 6 codes can be entered

12
Special Handling Instructions and Additional
Information Item 14

• Use to enter waste profile numbers, waste codes
  requiring treatment not included in Item 13,
  container codes, ERGs, barcodes, chemical
  names, constituent percentages, physical state or
  specific gravity of waste or other information
  necessary for the proper management or tracking
  of wastes.
• Can be used for certain federally required
  information, including PCB descriptions and
  out-of-service dates under 40 CFR 761.207,
  asbestos transporter address or original manifest
  tracking number for rejected wastes on the new
  manifest.

13
Generators / Offerors CertificationItem 15

• The generator must read, sign, and date the waste
  minimization certification statement. In signing
  the waste minimization certification statement,
  those generators who have not been exempted by
  statute or regulation from the duty to make a
  waste minimization certification under section
  3002(b) of RCRA are also certifying that they
  have complied with the waste minimization
  requirements.
• When a party other than the generator prepares
  the shipment for transportation, this party may
  also sign the shippers certification statement
  as the offeror of the shipment.
• Generator or Offeror personnel may preprint or
  handwrite the words, On behalf of in the
  signature block.

14
Exception Reporting

• If the generator does not receive a signed
  manifest from the final destination of the
  hazardous waste
• After 35 days, the generator must attempt to
  locate the hazardous waste by contacting the
  permitted facility.
• After 45 days for LQGs or 60 days for SQGs, the
  generator must submit to your EPA Regional Office
  an Exception Report that contains a copy of the
  original manifest and a cover letter describing
  your efforts to locate the shipment and the
  results of your efforts.

15
Generators Responsibilities

• Items 1 thru 15 must
• be completed by the generator prior to the waste
  being shipped.
• There should be no blanks. If an item is not
  applicable then the Letters NA should be
  entered in that space.

16
Transporter Responsibilities

• The following should be completed by the driver
  prior to leaving the generating location.
• Review items 1-15 for completeness and when
  possible accuracy
• Visually inspect load to insure conformance to
  approval. For bulk loads this may require
  looking in the box. For drum loads this may
  require checking approval numbers and other
  markings on the manifest to assure conformance.
• Complete item 17 on the manifest.

17
International Shipments

• Identify if waste is an Import or Export
• Port of entry/exit
• Transporter signature
• Date waste is leaving the US
• Transporter must submit copy of manifest tracking
  document to US Customs for exports

18
Disposal Site Responsibilities

• The following should be completed by the disposal
  facility prior to receiving the waste
• Review items 1-17 for completeness and accuracy
• Inspect load to insure conformance to approval.
  This usually involves visual inspection of waste
  and when necessary analytical testing
• Complete items 18 thru 20 on the manifest.

19
Discrepancies/Load Rejections

• The Discrepancy section of the manifest has been
  revised to obtain specific information
• Nature of Discrepancy
• Quantity
• Type
• Load Rejection
• Residue
• Partial Rejection
• Full Rejection
• At Sub-title D facilities these rejections must
  occur before the load is received.

20
Discrepancies/Load Rejections
21
Rejections

• Designated Facility Definition revised to allow
  generators to accept rejected waste.
• Generators may store rejected waste for up to 90
  Days (LQG), or 180 Days (SQG)
• Waste must be rejected from TSDF within 60 days
  of receipt.
• TSDF does not need permission to return the
  shipment to the generator.
• WM will make all possible attempts to contact the
  generator prior to rejecting a load

22
Full Load Rejections (If transporter is still on
site)
x

• A full load may be rejected on the original
  incoming manifest provided the original
  transporter is still on site.
• Item 18A must identify Full Rejection
• The rejecting TSDF will complete item 18b by
  entering the Alternate Facility (or Generator)
• The Alternate Facility or Generator will sign and
  date item 18c of manifest upon receipt.

23
Full Load Rejections(After Transporter has left
TSDF)

• A new manifest MUST be prepared for full load
  rejections once the original transporter has left
  the TSDF
• Item 18A of original manifest identify Full
  Rejection and reference the New Manifest
  Tracking Number.
• Special Handling and Additional Information
  section of new manifest must indicate the
  material is rejected waste and indicate the
  original manifest tracking number in Item 14.
• Complete all sections of the newly prepared
  manifest.
• Sign manifest as Offeror.

24
Partial Load Rejections (1)
Xx

• When a partial load rejection takes place the
  following steps must be taken.
• The partial load rejection box in item 18a should
  be checked.
• A second manifest will need to be generated for
  the rejected material.

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Partial Load Rejections (2)

• In Item 18a enter
• The reason for the rejection, the line item, and
  the description of the waste being rejected
• Enter New Manifest Tracking Number. This is the
  number of the new manifest the material will be
  rejected on.

26
Partial Load Rejections (3)New Manifest

• For the new manifest TSDF information is entered
  into generator items 1 and 5 the original
  generator information into Item 8 and items 9 -
  13 completed for the rejected material.
• In Item 14 enter the original manifest tracking
  number.
• TSDF completes Item 15 is as the offeror.

27
Hazardous Waste Report Management Method Codes

• Final Rule mandates the entry of the Hazardous
  Waste Report Management codes on the manifest in
  Item 19.
• Requires TSDF to complete Item 19 of manifest.
• Code corresponds with the final disposition of
  the waste by the designated facility on the
  manifest.

28
Item 20

• Designated facility should always complete item
  20 even if the load is a full or partial
  rejection.

29
Copies of the Manifest

• Each copy of the manifest and continuation sheet
  must indicate how the copy must be distributed,
  as follows
• Page 1 (top copy) Designated facility to
  destination State (if required).
• Page 2 Designated facility to generator state
  (if required).
• Page 3 Designated facility to generator.
• Page 4 Designated facility's copy.
• Page 5 Transporter's copy.
• Page 6 (bottom copy) Generator's initial copy.

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Continuation Page (1)

• Includes many of the same data elements as the
  manifest form
• Merely adds additional fields to identify
  additional transporters or waste streams which do
  not fit on the manifest
• Form will continue to be used in the same way as
  the previous continuation sheet.

31
Continuation Page (2)

• Increased number of rows from nine to ten
• Requires the preparer to number rows.
• Numbering of waste on first continuation sheet
  should start with Waste 5 and continue forward
  until all waste is identified.
• Discrepancy field does not include check boxes
• Manifest forms Discrepancy field provides ample
  space for information from page if needed.

32
Where do I get the new manifest?

• Upon Request Waste Management will prepare and
  provide customers manifest for loads being
  shipped to WM facilities.
• A list of manifest printers may be found at
  ---www.epa.gov/epaoswer/hazwaste/gener/manifest/re
  gistry/printers.htm
• WM encourages generators to ship waste and
  utilize old manifest forms prior to Sept. 5th
  when and where possible.
• Utilize stock of already purchased manifest
• Reduce the possibility of manifest shortage
  issues

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Summary

• Hazardous waste or Texas Class 1 must be shipped
  on an EPA Uniform Hazardous Waste Manifest
  (UHWM).
• The new manifesting rules go into effect
  September 5th 2006.
• The generator is responsible for completing items
  1-15 of the manifest.
• The transporter is responsible for item 17
• The designated facility is responsible for items
  18 20
• Full Load rejections may be done on the original
  manifest if the driver is still at TSDF location
• Partial Load rejections require a new manifest
• The manifest is a 6 copy document with each page
  having a designated recipient.

34
Frequently Asked Questions

• ?
• ? ?
• ? ? ?
• ? ?
• ?

35
Q When do the new manifest rules take effect?

• A
• Loads offered for transportation before
  09/05/2006 must still be shipped on the old
  manifest.
• Loads offered for transportation on or after
  September 5, 2006 must be on the new manifest.

• S
• E
• P
• T.

5 th
36
Q What will happen to my load if I ship on
an old manifest after Sept. 4, 2006?

• A The load will be discrepant, causing it to be
  delayed or possibly rejected if a new manifest is
  not sent to the landfill.

37
Q What will happen if I ship on a new manifest
prior to Sept. 5, 2006

• A Problems - The load will be discrepant,
  causing it to be delayed or possibly rejected,
  until the correct version of the manifest is
  received at the landfill.

38
Q What will happen if I ship a load of
hazardous waste or Texas Class 1 on Aug. 31, 2006
which will not arrive at the TSDF until Sept.7,
2006?

• A If the load is shipped on an old manifest it
  will be processed normally. If shipped on a new
  manifest it will be discrepant.
• Remember it is the date the material is offered
  for transportation that determines the correct
  manifest to use.

39
Q Where do I put the transporter
address if I am shipping RACM?

• A
• In Louisiana continue to use the ADVF form for
  the transporter address
• In Texas the transporter address should be placed
  in item 14 of the manifest

40
Q What Shipping forms do I use for
RCRA Hazardous RACM?

• A
• Waste generated and/or disposed of in Louisiana
  requires an ADVF form and a Hazardous Waste
  manifest.
• Waste generated and disposed of in Texas only
  requires a Hazardous Waste Manifest.

41
Q How will this affect my universal waste?

• A All universal waste rules (40 CFR part 273)
  and exceptions still apply.

42
Q Do I use the Texas Registration Numbers
OR EPA ID numbers?

• A If one or more hazardous waste are being
  shipped, EPA ID numbers will be entered for the
  Generator, Transporter and Receiver. If no
  hazardous waste is being shipped on the manifest,
  the 5 digit Texas registration numbers will be
  used.

43
Q If the generator knows that neither the
generator state nor the destination state require
a copy, do they still need to use the top two
copies? Or, could they just tear them off and
fill in the four required copies, in order to
make a better imprint?

• A Yes and NO
• The generator must comply with 40 CFR 262.23(b)
  and "give the transporter the remaining copies of
  the manifest." 262.23 Use of the manifest.
• (a) The generator must
• (1) Sign the manifest certification by hand and
• (2) Obtain the handwritten signature of the
  initial transporter and date of acceptance on the
  manifest and
• (3) Retain one copy, in accordance with
  262.40(a).
• (b) The generator must give the transporter the
  remaining copies of the manifest.