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Tracking Hazardous Chemical Waste

Generators of hazardous waste are responsible for waste generated at their site from cradle to grave, meaning that the generator is responsible for waste until it is ultimately disposed of.  A manifest using EPA form 8700-22, and 8700-22A if necessary, is required every time a hazardous waste generator offers waste for transportation for off-site treatment, storage, or disposal.

There are numerous requirements established for the manifest system.  310 CMR 30.331 requires that manifests be kept by the generator for three years from the date the waste was accepted by the transporter.  Many facilities decide to maintain manifests indefinitely due to the fact that generators are responsible for their waste cradle to grave.  This enables them to have documentation of the characteristics of the waste and destination disposal facility should any issues arise.

It is critical to ensure that manifests are completed appropriately.  The Treatment, Storage, and Disposal Facility (TSDF) that handles the disposal of the waste uses the characteristics and codes listed on the manifest to treat the waste appropriately.  The safety of the individuals handling the waste once it is removed for off-site disposal relies on correct information on manifests.  Remember that any hazmat employee signing waste manifests is required to be current in Department of Transportation (DOT) training and certified by the company.  All employees involved in the hazardous waste program should be trained on RCRA regulations as appropriate for their role in the program.

On February 7, 2014, EPA published Final Rule 79 FR 7517-7563 establishing new requirements for the use of electronic manifests (e-Manifests) to track off-site shipments of hazardous waste.  The final rule will become effective on August 6, 2014, however implementation will be delayed until the e-Manifest system is ready for operation and a fee schedule has been established.  According to the final rule, EPA will publish a further document after the effective date to announce the user fee schedule and compliance date for use of the e-Manifest system in accordance with 40 CFR 3.2(a)(2).  EPA has a deadline of October 2015 to establish the e-Manifest system.

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