Hazardous Waste Management-Manifesting Requirements

The purpose of the Hazardous Waste Manifest is to track hazardous waste from the generator site until it reaches the facility where it will be stored, treated or disposed of. The Uniform Hazardous Waste Manifest is a form that is required by the Environmental Protection Agency (EPA) and the Department of Transportation (DOT) for all generators, regardless of their generator status, who transport hazardous waste to an off-site facility for recycling, storage, treatment or disposal.

The waste manifest is a single form containing multiple copies. The form contains information regarding descriptions and volumes of the waste that is handled and the treatment or disposal requirements. In addition, the manifest contains signatures of all parties that were required to handle the waste. Each person who signs the manifest is required to retain a copy of the manifest for their records. Once the waste is received by the destination facility, a representative signs the manifest and returns the signed manifest to the generator, which affirms that the waste has been received.

Unfortunately, there are specific training requirements for employees who sign the hazardous waste manifest that are often overlooked. Training requirements are defined by the Federal Resource Conservation and Recovery Act (RCRA) Subtitle C and DOT regulations. Depending on your generator status there are various requirements for training under RCRA regulations. These training requirements are defined in 40 CFR Part 261 or Part 265.

As a hazardous waste generator you are also considered a “shipper” of hazardous materials under DOT’s hazardous materials transportation regulations. Specific requirements for hazardous materials employees can be found in 49 CFR Part 172, Subpart H. This training must be conducted within 90 days of employment and renewed every three years.

By signing the hazardous waste manifest, the employee is stating that they are trained on the aforementioned requirements. The employee signing the manifest is also verifying that all hazardous materials being transported are properly packaged, labeled, classified, and in proper condition to be transported according to 49 CFR Part 172.204. The signor of the manifest can now be held personally liable for compliance.

Learn about other Texas industrial and hazardous waste generator laws and risks here.

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By Russell Carr|2020-08-10T16:08:10-05:00January 6th, 2016|Good To Know|Comments Off

About the Author: Russell Carr

How A Sales Guy Transformed Into An Environmental, Health & Safety Expert & Advocate For Small Businesses I've spent my entire 30+ year career working within the manufacturing and “industrial services” sectors. The first 15 years of my career focused on sales of hazardous materials related products and services to the manufacturing sector, then for the last 16+ years transitioned into entrepreneurship, founding 3 small industrial services related contracting businesses. As you’ll see below, running these companies eventually lead me to found yet a 4th business, but more on that in a minute…. Here’s a brief description of the first 3 companies: Berg Environmental Services, Inc.: hazardous waste disposal & transportation services, founded in August of 2003 3rd party wind energy operations & maintenance services provider to utility scale wind farms throughout the US, founded in September 2007 3rd party oil & gas exploration & production services provider, founded in August of 2011 Each of these companies operated in extremely dangerous working conditions and exposed my employees to a wide range of serious health & safety hazards on a daily basis. To complicate matters, 2 of the companies also exposed the environment to significant potential harm. In other words, I learned very early the critical importance of managing environmental, health and safety issues so as to ensure the safety of our employees and the environment, as well as minimizing related risks. But I also learned how incredibly difficult and challenging this endeavor can be due to the wide range of complicated and continually changing environmental, health and safety rules and regulations that impacted the companies. To summarize the challenges: First I had to determine which regulations applied to each company, then I had to build compliance programs to meet those regulations, and finally I had to ensure that the programs were being managed and followed by our staff on a daily basis. All while trying to run and grow 3 profitable businesses…. It was overwhelming and I always struggled to keep up. To make matters worse, throughout this time I also witnessed the devastating price that companies, management and ownership can pay for failing to manage EHS compliance. This included seeing one of my hazardous waste management clients get sent to jail over environmental issues, another client’s management team threatened with jail time, a direct competitor get fined $378,000 by OSHA fine after an employee was nearly killed, and many others face major fines and penalties. Full disclosure, one of my companies got fined by OSHA at one point, & another was cited by TCEQ, so I know how it feels. In summary, I learned first hand how incredibly difficult it is for small companies to manage EHS compliance due to a common lack of the critical expertise, time and resources that are needed to keep up, and how this situation then ends up exposing them to these potentially catastrophic risks that can literally destroy lives and businesses. This later inspired me to found my 4th company, Berg Compliance Solutions in 2012, which is dedicated to helping other small businesses, and business owners, to manage EHS compliance and risk. Education BA, Philosophy, University of Colorado, Boulder, December, 1990. Summary of Professional Experience & Qualifications: 30+ years serving the manufacturing & industrial services sectors 30+ years of sales and marketing experience 16+ years as small business owner & entrepreneur: Founded and operated 4 small businesses since 2003. Environmental, Health & Safety Compliance & Program Related: 19 plus years of hazardous waste management including EPA, TCEQ & RCRA regulations 8 years of DOT/FMCSA compliance experience, including hazardous materials transportation 8 years of combined experience implementing and managing OSHA health and safety compliance programs for 2 high risk energy services businesses Successfully implemented and gained ISO 9001 Quality Management Certification and OHSAS 18001 (Occupational Health & Safety Advisory Service) Certification for wind energy maintenance business. Regulatory Enforcement Related Experience: Served as expert witness in criminal environmental compliance enforcement cases Superfund-CERCLA OSHA enforcement inspections, investigations and resolution in following industries: industrial services, manufacturing & construction. TCEQ enforcement inspections, investigations and resolution in manufacturing.

Hazardous Waste Management-Manifesting Requirements