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

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. 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.

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. 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)

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. Identifying hazardous waste

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. The manifest form 40 CFR part 262, Appendix A

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. 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).

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. 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 (a)(1))

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. Where do I get the forms? manifest/registry/printers.htm

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. Get rid of that waste Item 1 of the manifest: Generator’s US EPA Identification number (40 CFR ) KS Item 2: Page 1 of __

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. 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. KS (888)

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. Manifest Item 4 The manifest tracking number is pre-printed on the form. 1 (888) JJK

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. Manifest Item 5 Enter the address where the designated facility should mail the completed manifest after they receive your waste. P.O. Box Back Lane Somewhere, TX Somewhere, TX (888) Enter the “site address” only if it is different from the “mailing address.”

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. Manifest Item 6 and 7 Transporter information Big Truck Haulers, Inc. MN

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. Continuation sheets Space for additional: Transporters Waste streams

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. Continuation sheets continued Enter the Manifest Tracking Number from Item 4 of the manifest here, in Item 23 of the continuation sheet

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. Manifest Item 8 Designated facility Safe Disposal, Inc. 111 Sunny Drive, Anytown, KS KS (888)

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. Manifest Item 9 US DOT description of your waste X Waste acetone, 3, UN1090, PGII (49 CFR part 172)

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. 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

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. 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

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. Manifest Item 13 Federal waste codes have priority X Waste Acetone, 3, UN1090, PGII 1 DM 40 G D001

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. 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.

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. Manifest Item 14 Special handling instructions could include: Waste profile numbers Container codes ERG numbers sp. gravity 0.79, waste profile number SW83

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. 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

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. 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.

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. Required training The person signing the manifest must receive: function-specific training, and general awareness/safety training. (49 CFR and )

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. 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 and )

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. 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

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. 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

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. Pre-printing

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. 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

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. “True” story The Case of the Messed Up Manifest with Lieutenant Mouldy and Officer Sculler

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. Shipping papers for all hazmat

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. A manifest for all haz waste

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. Make it obvious X Waste acetone, UN1203, PGII 1 DM 55 G D001 Sand 3 CW 3 Y

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. 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)

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. Signing the manifest Notsogood, Inc., Joe Manager Joe Manager

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. 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.

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. Case closed

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. 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

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. A manifest for non-hazardous waste? Ship non-hazardous waste on a manifest?? Illinois Texas Michigan Check with your state!

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. 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)

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. 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.

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. Details of proposal 2001 proposal included: Electronic file formats Electronic signature options Computer security controls

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. 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.

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. 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.

Copyright © 2007 J. J. Keller & Associates, Inc. All rights reserved. Questions?