Managing the manifest: The ins and outs of EPA's new form

1. Managing the manifest: The ins and outs of EPA's new form

2. Today’s agenda • Learn how to properly complete and use the new form. • Hear the answers to common questions. • Hear “The Case of the Messed-Up Manifest.” • Get an update on the proposed electronic manifest system.

3. Hazardous waste manifest system Tracks waste: • from where it was generated • to where it ends up • using the uniform hazardous waste manifest. (40 CFR parts 262, 263, 264, 265)

4. Identifying hazardous waste

5. The manifest form 40 CFR part 262, Appendix A

6. What’s on the form? The manifest provides information about: • the generator of the waste, • the facility that will receive the waste, • the description and quantity of the waste, and • how the waste will get to the receiving facility (the transporters).

7. Who’s responsible? You must prepare a manifest if you are: • a generator who transports (or offers for transport) a hazardous waste for offsite treatment, storage, or disposal; or • a treatment, storage, and disposal facility (TSDF) who offers for transport a rejected hazardous waste load. (40 CFR 262.20(a)(1))

8. Where do I get the forms? www.epa.gov/epaoswer/hazwaste/gener/ manifest/registry/printers.htm

9. Get rid of that waste Item 1 of the manifest: • Generator’s US EPA Identification number (40 CFR 262.12) KS0888777444 1 Item 2: • Page 1 of __

10. Manifest Item 3 The emergency response phone number must: • be the number of the generator OR the number of an agency or organization who can provide detailed information about the shipment; • reach a phone that is monitored 24 hours a day, seven days a week, at all times the waste is in transportation; AND • reach someone who either knows of the hazardous waste being shipped and has emergency response information for the material being shipped OR has immediate access to a person who has that knowledge and information about the shipment. KS0888777444 1 (888) 222-1111

11. Manifest Item 4 The manifest tracking number is pre-printed on the form. 1 (888) 222-1111 002251476 JJK

12. Manifest Item 5 Enter the address where the designated facility should mail the completed manifest after they receive your waste. P.O. Box 111 345 Back Lane Somewhere, TX 77654 Somewhere, TX 77654 (888) 842-8420 Enter the “site address” only if it is different from the “mailing address.”

13. Manifest Item 6 and 7 Transporter information Big Truck Haulers, Inc. MN0333444555

14. Continuation sheets Space for additional: • Transporters • Waste streams

15. Continuation sheets continued Enter the Manifest Tracking Number from Item 4 of the manifest here, in Item 23 of the continuation sheet

16. Manifest Item 8 Designated facility Safe Disposal, Inc. 111 Sunny Drive, Anytown, KS KS0888777555 (888) 777-4444

17. Manifest Item 9 US DOT description of your waste X Waste acetone, 3, UN1090, PGII (49 CFR part 172)

18. Manifest Item 10 Types of containers: • BA = Burlap, cloth, paper, or plastic bags • CF = Fiber or plastic boxes, cartons, cases • CM = Metal boxes, cartons, cases (includings roll-offs) • CW = Wooden boxes, cartons, cases • CY = Cylinders • DF = Fiberboard or plastic drums, barrels, kegs • DM = Metal drums, barrels, kegs • DT = Dump truck • DW = Wooden drums, barrels, kegs • HG = Hopper or gondola cars • TC = Tank cars • TP = Portable tanks • TT = Cargo tanks X Waste Acetone, 3, UN1090, PGII 1 DM

19. Manifest Item 11 and 12 Units of measure for Item 12: • G = Gallons (liquids only) • K = Kilograms • L = Liters (liquids only) • M = Metric Tons • N = Cubic Meters • P = Pounds • T = Tons • Y = Cubic Yards X Waste Acetone, 3, UN1090, PGII 1 DM 40 G

20. Manifest Item 13 Federal waste codes have priority X Waste Acetone, 3, UN1090, PGII 1 DM 40 G D001

21. More Item 13 Q: What if more than six waste codes apply? A: Choose the top six that most accurately represent the hazards of the waste.

22. Manifest Item 14 Special handling instructions could include: • Waste profile numbers • Container codes • ERG numbers sp. gravity 0.79, waste profile number SW83

23. More Item 14 Additional descriptive information could include: • Chemical names • Constituent percentages • Physical state • Specific gravity Other federally-required information could include: • Alternate facility designations • The manifest tracking number of the original manifest (for rejected wastes and residues that are re-shipped under a second manifest) • PCB waste descriptions and out-of-service dates required under PCB rules

24. Manifest Item 15 By signing the certification, you are: • certifying that you have complied with waste minimization requirements, and • attesting that the shipment has been properly prepared and is in proper condition for transportation.

25. Required training The person signing the manifest must receive: • function-specific training, and • general awareness/safety training. (49 CFR 172.204 and 172.704)

26. More about training Your signature certifies that the materials being shipped are: • properly classified, described, packaged, marked, and labeled; and • in proper condition for shipment. (49 CFR 172.204 and 172.704)

27. Copies for each handler Manifest plies (in order, top to bottom): • Designated facility to destination state (if required) • Designated facility to generator state (if required) • Designated facility to generator • Designated facility’s copy • Transporter’s copy • Generator’s initial copy

28. The path of the manifest Generator → Transporter Transporter → TSD facility TSD Facility→ Generator → Generator state (if required) → Destination state (if required) KOL→ Reference→ State-Specific Reference Area→ Environment→ Hazardous Waste→ Manifest Information

29. Pre-printing

30. More pre-printing These items may NOT be pre-printed: • Item 2: Page 1 of __ • Item 10: Containers (No. and type) • Item 11: Total Quantity • Item 12: Unit (Wt./Volume) • Item 15: Generator’s/Offeror’s Certification • Item17: Transporter Acknowledgement of Receipt of Materials • Item 18a: Discrepancy Indication Space • Item 18b: Alternate Facility (or Generator) • Item 18c: Signature of Alternate Facility (or Generator) • Item 19: Hazardous Waste Report Management Method Codes • Item 20: Designated Facility Owner or Operator: Certification of Receipt

31. “True” story The Case of the Messed Up Manifest with Lieutenant Mouldy and Officer Sculler

32. Shipping papers for all hazmat

33. A manifest for all haz waste

34. Make it obvious X Waste acetone, UN1203, PGII 1 DM 55 G D001 Sand 3 CW 3 Y

35. Shipping description • Proper shipping name • Hazard class/division number • Subsidiary hazard class/division number • UN/NA number • Packing group • Total quantity and unit of measurement • Number and type of packages (49 CFR 172)

36. Signing the manifest Notsogood, Inc., Joe Manager Joe Manager

37. Emergency response phone # NOT authorized: • Beepers • Answering machines • Switchboards If you use the number of a service provider, such as CHEMTREC, you MUST have a valid contract in force with that provider.

38. Case closed

39. Manifests: State stuff States may still have their own requirements: • Submit copies to the state • State-specific waste codes KellerOnline → Reference → State-specific → Environment → Hazardous waste (RCRA) Manifest Information

40. A manifest for non-hazardous waste? Ship non-hazardous waste on a manifest?? • Illinois • Texas • Michigan Check with your state!

41. Manifest use summary Hazardous waste → Manifest Non-hazardous waste → Manifest? → State-specific form? → Any shipping paper? KellerOnline→ State information→ Environment area → Shipping document note (under Solid (non-hazardous) waste heading)

42. Update: Electronic manifests Current rule: • Paper forms • Signed by hand • Filed in operating records A proposed rule change would make electronic manifests acceptable as the legal equivalent of paper forms.

43. Details of proposal 2001 proposal included: • Electronic file formats • Electronic signature options • Computer security controls

44. E-manifest: Preferred option Preferred option: A national e-Manifest system: • developed and operated under federal contract, • funded by user fees, and • hosted on EPA’s Central Data Exchange reporting system.

45. E-manifest: Other options Other options for an electronic system include: • a privately-developed national system, • a decentralized option - Various private entities would develop numerous e-Manifest systems that meet EPA standards, and • no action - Manifesting would continue only with paper manifests. Final rule is planned for 2008.

46. ? Questions? ? ? ? ? ? ? ? ? ? ? ? ?