DSHW-2024-006628

Manifests
Cradle to grave
01.02.03.Generator Transporter 04.05.Transporter Transporter TSDF
Manifests!
Joint Regulations
RCRA DOT
R315-262-20 through 17 49 CFR 172
Keep signed copy, with all
signatures for 3 years
Ensure all information is
correct prior to signing
What now?
Track the days since you
signed the manifest
Note: electronic copies of
manifests are OK, but you
must be able to easily
provide the signed copies
when requested.
Exception Reports R315-262-42
LQG:
•After 35 days –contact
transporter and/or TSDF
•After 45 days –Exception
Report to Division
SQG:
•After 60 days –Exception
Report to Division
The Report:
•LEGIBLE copy of the manifest
•Cover leer signed by
generator explaining eorts
to locate wastes and results
Submit by mail or electronically
to [e-mail]
Keep for 3 years!
LDR Forms
LDR = Land Disposal Restriction
Track when a waste has been suiciently treated to land dispose
•Type of waste, waste codes at generation
•What treatments the waste has gone through
Many nuances, assuming for this presentation that your waste does
not meet treatment standards for land disposal (it probably doesn’t)
R 315-268 -7
Manifest number
EPA waste codes
The constituents of concern for F001-F005, and F039, and underlying hazardous
constituents in characteristic wastes.
Applicable wastewater/nonwastewater category
The waste is subject to LDRs
“Pursuant to 40 CFR 268.7(a), I hereby notify that this shipment contains waste
restricted under 40 CFR Part 268.”
Waste analysis data, if available
Should include:
Keep signed copy for 3 years
One per waste stream per
disposal facility*
What now?
Ensure all information is
correct prior to signing!
In practice, most TSDFs prefer a
copy with each manifest
Info should match info on
manifest
Ideally kept with corresponding
manifest
DOT Training
Who is signing
these things?
Joint Regulations
RCRA DOT
R315-262-23 certification
Hazardous waste is a subset of hazardous materials.
49 CFR 172 Subpart H
Safety training
General awareness
/familiarization training
DOT Requirements
Function-specific training
49 CFR 172.704
Must be renewed every ο years
If you don’t
have all
training in all
parts, you
should not be
signing
manifests!
Generator’s certification
(or “shipper’s” cert.)
DOT + RCRA
Certifying materials are properly:
•classified,
•described
•packaged
•marked and labeled
•in proper condition
Certifying to waste minimization
certification in R315-262 -27
Transporters
Transporters
Any person engaged in the osite transportation of
hazardous waste by air, rail, highway, or water.
EPA ID Number
40 CFR 263 (a summary)
Storage < 10 days
(Transfer
Facilities)
Manifests
Recordkeeping
Spill Response
*Manifest stays with waste at all
times!*
Repacking wastes
Rejected wastes
Additional actions
Spliing shipments
Acting on behalf of
a generator
10-Day Transfer Facilities
Any transportation related facility where HW or HSMs
held during the normal course of transportation
What are they?
RO #11529/#11846
Inconsistent with the “normal course of transportation”
Possession of the waste is
changing from one
transporter to another while
the waste remains at one site.
Waste is routed to
numerous transporters for
extended periods of time.
Waste is routed to the
same geographic location
more than once during the
course of transportation.
ABC Transport
ABC Transport
ABC Transport
ABC Transport
ABC Transport
ABC Transport
The Numbers
data reflects 12
months from 5/2/24
retrieved from
RCRAinfo Metabase
So… what can
I do about it?
Check manifests
for accuracy and
completeness
before signing!
Keep track of your
waste!
Get your complete
return copies.
File ERs as needed.
Don’t be afraid to
talk to your
transporters and
TSDFs!
https://deq.utah.gov/division-waste-management-radiation-control
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[phone]
[e-mail]