1. HAZARDOUS WASTE TRANSPORTATION CUSTOMIZED ENVIRONMENTAL
TRAINING
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WELCOME 1 1 1 1

2. Insert Instructor Name Here
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3. OBJECTIVES Discuss the EPA ID Number Requirements for Transporters.
Discuss Packaging, Labeling, Marking and Placarding Requirements for Transporters.
Discuss Compliance With the Hazardous Waste Manifest.
Discuss the Transporter’s Responsibilities if a Hazardous Waste Discharge Occurs.
Discuss the Manifest Requirements for Different Modes of Transportation.
Discuss Transfer Facilities Responsibilities.
Discuss Transporter Training Requirements.
Discuss Reports and Recordkeeping.
Recommend Inspection Items.
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4. GOALS Understand the EPA ID Number Requirements for Transporters.
Be Familiar With the Packaging, Labeling, Marking and Placarding Requirements for Transporters.
Understand Compliance With the Hazardous Waste Manifest.
Understand the Transporter’s Responsibilities if a Hazardous Waste Discharge Occurs.
Understand the Manifest Requirements for Different Modes of Transportation.
Understand Transfer Facilities Responsibilities.
Understand Transporter Training Requirements.
Understand Reports and Recordkeeping Requirements.
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5. BACKGROUND
In 1998, 61,234 industries reported a total of 7.3 billion pounds of hazardous chemicals released to the air, land and water in the United States.
The Department of Transportation annually issues over 500 warning letters, 100 tickets, 1,400 penalties and collects over $7 million in total penalties for non-compliance of hazardous waste transportation requirements.
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6. LEARNERS Supervisors Facility Engineers Maintenance Personnel
Department Managers
Building Occupants
Process Specialists
Environmental and Safety Committees
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7. OVERVIEW
The goal of this course is to provide supervisors with the tools needed to safely transport hazardous waste and remain in compliance. It recommends practical, actions that can be carried out by facility management, maintenance personnel and building occupants. The course will help you integrate good hazardous waste transportation management activities into your existing organization and identify which of your staff have the necessary skills to carry out those activities.
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8. WHAT THIS COURSE DOES NOT DO
The course is not intended to provide information detailed information on packaging, labeling, and placarding of each hazardous waste. Nor is it specific training for hazardous waste spills and cleanup. These specialties required training beyond the intended scope of this course. Where this expertise is needed, outside assistance should be solicited.
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9. RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
RCRA addresses the management of hazardous waste and the transportation of hazardous waste
The Resource Conservation and Recovery Act, Subtitle C (1976)
The Resource, Conservation and Recovery Act (RCRA) of 1976 addresses the management of hazardous waste including the transportation of hazardous waste.

10. FEDERAL REGULATIONS Pertinent Regulations:
40 CFR 263 – Standards Applicable to Transporters of Hazardous Waste
40 CFR 262 – Standards Applicable to Generators of Hazardous Waste
49 CFR – Department of Transportation Hazardous Materials Regulations
This training will look at three sections of federal regulations: The primary EPA regulation 40 CFR 263 – Standards Applicable to Transporters of Hazardous Waste
Also important is 40 CFR 262 – Standards Applicable to Generators of Hazardous Waste that discusses packaging, labeling, marking, placarding, recordkeeping and reports.
49 CFR – Department of Transportation Hazardous Materials Regulations discusses specific requirements for shipping hazardous waste.

11. OVERVIEW
EPA has promulgated regulations governing the safe transport of hazardous wastes from generator to designated facility
Section 263 applies to carriers transporting hazardous waste within the United States when that waste is subject to the manifesting requirements of Section 262
Transportation means "the movement of hazardous waste by air, rail, highway, or water”
EPA promulgated the transporter requirements to be consistent with appropriate DOT regulations
In general, transporters of hazardous waste must comply with the requirements of Part 263, as well as the specific DOT requirements
Part of RCRA
As part of Resource Conservation Recovery Act's (RCRA) comprehensive hazardous waste management program, EPA promulgated regulations governing the safe transport of hazardous wastes from generator to designated facility, which is usually a treatment, storage, or disposal facility (TSDF).
Section 263 applies to carriers transporting hazardous waste within the United States when that waste is subject to the manifesting requirements of Section 262.
Transportation means "the movement of hazardous waste by air, rail, highway, or water” (Section ).
EPA promulgated the transporter requirements to be consistent with appropriate DOT regulations.
In general, transporters of hazardous waste must comply with the requirements of Part 263, as well as the specific DOT requirements referenced throughout the transporter regulations.

12. OVERVIEW
DOT has incorporated RCRA hazardous wastes as one of the types of hazardous materials that must be transported according to DOT specifications
The Joint Uniform Hazardous Waste Manifest serves as both the EPA tracking form and the shipping paper required under DOT
This system allows the in-transit management of hazardous waste to be regulated safely and efficiently while allowing both EPA and DOT to retain enforcement of their respective regulations
D.O.T.
In addition, the Department Of Transportation (DOT) incorporates RCRA hazardous wastes as one of the types of hazardous materials that must be transported according to DOT specifications (49 CFR Section 171.3).
The Joint Uniform Hazardous Waste Manifest, promulgated on March 20, 1984 (49 CFR 10490), serves as both the EPA tracking form (Section ) and the shipping paper required under DOT (49 CFR Section ).
This system allows the in-transit management of hazardous waste to be regulated safely and efficiently while allowing both EPA and DOT to retain enforcement of their respective regulations.

13. OVERVIEW EPA regulates the off-site transportation of hazardous wastes
Part 263 does not apply to the on-site movement of wastes within a facility's boundary
The term on-site includes the transport of hazardous waste between contiguous properties, even when separated by a public road "provided that the entrance and exit between the properties in at a crossroads intersection, and access is by crossing, as opposed to going along, the right-of-way"
Generally Part 263 does not apply to transportation of shipments that do not require a manifest
Different Hazardous Waste Transportation Regulations
Not all hazardous waste transportation is regulated in the same way. EPA regulates the off-site transportation of hazardous wastes.
Part 263 does not apply to the on-site movement of wastes within a facility's boundary. The term on-site includes the transport of hazardous waste between contiguous properties, even when separated by a public road "provided that the entrance and exit between the properties in at a crossroads intersection, and access is by crossing, as opposed to going along, the right-of-way" (Section ).
Generally Part 263 does not apply to transportation of shipments that do not require a manifest.

14. DEFINITIONS
Transport vehicle means a motor vehicle or rail car used for the transportation of cargo by any mode
Each cargo-carrying body (trailer, railroad freight car, etc.) is a separate transport vehicle
Transportation means the movement of hazardous waste by air, rail, highway, or water
Transporter means a person engaged in the offsite transportation of hazardous waste by air, rail, highway, or water
Definitions
Transport vehicle means a motor vehicle or rail car used for the transportation of cargo by any mode. Each cargo-carrying body (trailer, railroad freight car, etc.) is a separate transport vehicle.
Transportation means the movement of hazardous waste by air, rail, highway, or water.
Transporter means a person engaged in the offsite transportation of hazardous waste by air, rail, highway, or water.

15. EPA IDENTIFICATION NUMBER
A transporter is required to obtain an EPA ID number before transporting hazardous waste
Transporters obtain EPA ID numbers by completing and submitting EPA’s form the Notification of Regulated Waste Activity
EPA issues transporter ID numbers for primary offices or places of business, not individual transporting terminals
EPA IDENTIFICATION NUMBER
A transporter is required to obtain an EPA ID number before transporting hazardous waste (Section ).
Transporters obtain EPA ID numbers by completing and submitting the Notification of Regulated Waste Activity Form (EPA Form ).
EPA issues transporter ID numbers for primary offices or places of business, not individual transporting terminals. For example, separate truck terminals owned by the same company operate under the same EPA ID number (45 FR 12752; February 26, 1980); in contrast to generator ID numbers, which are generally site-specific.

16. PACKAGING
According to DOT’s 49 CFR 171.2(a), anyone who offers or accepts a hazardous material shipment must comply with the Hazardous Materials Regulations (HMR)
No person, individual or company may offer or accept a hazardous material for transportation in commerce unless the shipment complies with the HMR
The shipper and the carrier share in the responsibility to offer and/or accept only hazardous materials that comply with the HMR
According to DOT’s 49 CFR 171.2(a), anyone who offers or accepts a hazardous material shipment must comply with the Hazardous Materials Regulations (HMR).
No person, individual or company may offer or accept a hazardous material for transportation in commerce unless the shipment complies with the HMR.
The shipper and the carrier share in the responsibility to offer and/or accept only hazardous materials that comply with the HMR.

17. PACKAGING
Preparation of hazardous materials for transportation is the responsibility of the person who offers the material for transportation
Unless otherwise provided, a hazardous material may be offered for transportation in an approved packaging or container only if the material is:
properly classed,
properly described,
in a properly manufactured and tested packaging,
in a packaging marked in accordance with the HMR,
the package fully complies with 49 CFR Part 173, 178, and 179
Preparation
Preparation of hazardous materials for transportation is the responsibility of the person who offers the material for transportation.
Unless otherwise provided, a hazardous material may be offered for transportation in an approved packaging or container only if the material is:
properly classed,
properly described,
in a properly manufactured and tested packaging or container,
in a packaging marked in accordance with the DOT’s HMR, and
the package is in full compliance with 49 CFR Part 173, 178, and 179.

18. LABELING
Before transporting or offering hazardous waste for transportation off-site, a generator must label each package in accordance with the applicable Department of Transportation regulations on hazardous materials under 49 CFR part 172
Labeling
Before transporting or offering hazardous waste for transportation off-site, a generator must label each package in accordance with the applicable Department of Transportation regulations on hazardous materials under 49 CFR part 172.

19. MARKING
Before transporting or offering hazardous waste for transportation off-site, a generator must mark each package of hazardous waste
Before transporting hazardous waste or offering hazardous waste for transportation off-site, a generator must mark each container of 110 gallons or less used in such transportation with the following words:
HAZARDOUS WASTE—Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.
Generator’s Name and Address ___________.
Manifest Document Number ____________.
Marking
(a) Before transporting or offering hazardous waste for transportation off-site, a generator must mark each package of hazardous waste in accordance with the applicable Department of Transportation regulations on hazardous materials under 49 CFR part 172;
(b) Before transporting hazardous waste or offering hazardous waste for transportation off-site, a generator must mark each container of 110 gallons or less used in such transportation with the following words and information displayed in accordance with the requirements of 49 CFR :
HAZARDOUS WASTE—Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.
Generator’s Name and Address —————.
Manifest Document Number ——————.

20. PLACARDING
Before transporting hazardous waste or offering hazardous waste for transportation off-site, a generator must placard or offer the initial transporter the appropriate placards according to Department of Transportation regulations for hazardous materials under 49 CFR part 172, subpart F
Placarding
Before transporting hazardous waste or offering hazardous waste for transportation off-site, a generator must placard or offer the initial transporter the appropriate placards according to Department of Transportation regulations for hazardous materials under 49 CFR part 172, subpart F.

21. COMPLIANCE WITH THE MANIFEST
EPA created a tracking mechanism to ensure that hazardous waste sent to a treatment, storage, and disposal facility (TSDF) reaches its destination
The manifest is the central element of this system. The Uniform Hazardous Waste Manifest (EPA Form ) and its instructions are found in the appendix to 40 CFR Part 262
The manifest is the control and transport document that accompanies the waste during transport from its generation site to its final destination facility
Compliance With The Manifest
EPA created a tracking mechanism to ensure that hazardous waste sent to a treatment, storage, and disposal facility (TSDF) reaches its destination.
The manifest is the central element of this system. The Uniform Hazardous Waste Manifest (EPA Form ) and its instructions are found in the appendix to 40 CFR Part 262.
The manifest is the control and transport document that accompanies the waste during transport from its generation site to its final destination facility.

22. COMPLIANCE WITH THE MANIFEST
40 CFR Part 263, Subpart B, dictates transporter responsibilities for the manifest system
Before hazardous waste can be transported, the transporter must sign and date the manifest
The transporter must then deliver the hazardous waste shipment to the next transporter, the designated facility, or the alternate facility listed on the manifest
If the waste cannot be delivered to the designated receiver, the generator must be contacted for further instructions, and the manifest must be revised accordingly
The manifesting responsibilities vary depending on the mode of transportation
Compliance With The Manifest
40 CFR Part 263, Subpart B, dictates transporter responsibilities for the manifest system as well as recordkeeping requirements with which a hazardous waste transporter must comply.
Before hazardous waste can be transported, the transporter must sign and date the manifest. This enables the transporter to formally acknowledge the acceptance of hazardous waste from the generator and return a signed copy to the generator before leaving the generator's property (Section (b)).
The transporter must then deliver the hazardous waste shipment to the next transporter, the designated facility, or the alternate facility listed on the manifest or the place outside the United States designated by the generator (Section (a)).
If the waste cannot be delivered to the designated receiver, the generator must be contacted for further instructions, and the manifest must be revised accordingly (Section (b)).
The manifesting responsibilities vary depending on the mode of transportation (i.e., highway, water, rail, or air).

23. HAZARDOUS WASTE DISCHARGES
If a transporter discharges or spills hazardous waste, he or she is required to take immediate action to protect human health and the environment
"Immediate action" is not specifically defined, however, it may include containing the spill, notifying local authorities, and notifying the National Response Center as required by DOT or Superfund regulations
DOT may require a written report
Federal, state, or local authorities may require a transporter to take actions in response to a discharge or spill if the discharge is determined to present a long-term hazard to human health or the environment
HAZARDOUS WASTE DISCHARGES
If a transporter discharges or spills hazardous waste, he or she is required to take immediate action to protect human health and the environment (Section ).
"Immediate action" is not specifically defined, however, it may include containing the spill, notifying local authorities, and notifying the National Response Center as required by DOT or Superfund regulations.
DOT may require a written report (see Section for specific reporting requirements).
In addition, federal, state, or local authorities may require a transporter to take actions in response to a discharge or spill if the discharge is determined to present a long-term hazard to human health or the environment (Section ).
This may include authorization of a nonmanifested removal of the hazardous waste by a transporter without an EPA ID number when an immediate removal is deemed necessary to protect human health and the environment.

24. DISCHARGE CLEANUP
A transporter must clean up any hazardous waste discharge that occurs during transportation or take such action as may be required or approved by Federal, State, or local officials so that the hazardous waste discharge no longer presents a hazard to human health or the environment
Discharge Clean Up
A transporter must clean up any hazardous waste discharge that occurs during transportation or take such action as may be required or approved by Federal, State, or local officials so that the hazardous waste discharge no longer presents a hazard to human health or the environment.

25. MODES OF TRANSPORTATION
Transportation of hazardous waste from the generator to the designated facility can be accomplished by several means of transportation
The regulations establish guidelines for the proper handling and recordkeeping of hazardous waste transported by highway, water, rail, or air
MODES OF TRANSPORTATION
Transportation of hazardous waste from the generator to the designated facility can be accomplished by several means of transportation. The regulations establish guidelines for the proper handling and recordkeeping of hazardous waste transported by highway, water, rail, or air. The requirements for each method of transportation are discussed on the following slides.

26. HIGHWAY SHIPMENTS
Highway transporters must complete the following manifest and recordkeeping requirements:
Sign and date the manifest
Leave a signed and dated copy of the manifest with the generator
Ensure that the manifest accompanies the waste
Obtain the dated signature of the next transporter or the owner/operator of the designated facility, and
Keep a copy of the manifest for at least three years
HIGHWAY SHIPMENTS
Under 40 CFR Section , highway transporters must complete the following manifest and recordkeeping requirements:
* Sign and date the manifest
* Leave a signed and dated copy of the manifest with the generator
* Ensure that the manifest accompanies the waste
* Obtain the dated signature of the next transporter or the owner/operator of the designated facility, and
* Keep a copy of the manifest for at least three years (all three-year record retention requirements are extended in case of an enforcement action).

27. WATER (BULK) SHIPMENTS
Water transporters must comply with the directions on the manifest, obtain an EPA ID number, and be listed on the manifest
When shipping hazardous waste by water, however, the manifest is not required to physically accompany the shipment
Instead, the person delivering the waste to the initial water transporter obtains the date of delivery and signature of the water transporter on the manifest and forwards it to the designated facility
WATER (BULK) SHIPMENTS
In 40 CFR Section (e), EPA established regulations governing the shipment of hazardous waste by water.
Water transporters must comply with the directions on the manifest, obtain an EPA ID number, and be listed on the manifest.
When shipping hazardous waste by water, however, the manifest is not required to physically accompany the shipment.
Instead, the person delivering the waste to the initial water transporter obtains the date of delivery and signature of the water transporter on the manifest and forwards it to the designated facility.

28. WATER (BULK) SHIPMENTS
In addition, if the waste is delivered directly to the TSDF, the water transporter must:
Ensure that a shipping paper (e.g., waybill), containing the same information as the manifest, accompanies the waste
Obtain the dated signature of the owner or operator of the designated facility on the shipping paper or the manifest
Sign and date the manifest
Retain a copy of the shipping paper or manifest for three years
WATER (BULK) SHIPMENTS
In addition, if the waste is delivered directly to the TSDF, the water transporter must:
* Ensure that a shipping paper (e.g., waybill), containing the same information as the manifest, accompanies the waste (excluding the EPA ID number, generator certification, and signatures)
* Obtain the dated signature of the owner or operator of the designated facility on the shipping paper or the manifest
* Sign and date the manifest
* Retain a copy of the shipping paper or manifest for three years (Section (e)).

29. RAIL SHIPMENTS
As with the other methods of transport, rail transporters must have an EPA ID number and ensure the designated facility is listed on the manifest
Similar to water shipments, rail transporters must comply with the directions on the manifest and must be listed as a transporter on the manifest, but the actual manifest form does not have to accompany the waste shipments at all times
Instead, a standard waybill or other shipping document containing all the manifest information except EPA ID number, generator certification, and signatures may accompany the waste
RAIL SHIPMENTS
Rail transport is another method by which hazardous waste is shipped to the designated facility (Section (f)).
As with the other methods of transport, rail transporters must have an EPA ID number and ensure the designated facility is listed on the manifest. Similar to water shipments, rail transporters must comply with the directions on the manifest and must be listed as a transporter on the manifest, but the actual manifest form does not have to accompany the waste shipments at all times.
Instead, a standard waybill or other shipping document containing all the manifest information except EPA ID number, generator certification, and signatures may accompany the waste (45 FR 12739; February 26, 1980).

30. RAIL SHIPMENTS Initial rail transporter's duties include:
Signing and dating the manifest
Returning a signed copy of the manifest to the non-rail transporter
Retaining a copy of the manifest and rail shipping paper for three years
Forwarding at least three copies to the next non-rail transporter or designated facility (if the shipment is delivered by rail), or the last rail transporter designated to handle the waste in the United States
Initial rail transporter's duties include:
* Signing and dating the manifest
* Returning a signed copy of the manifest to the non-rail
transporter
* Retaining a copy of the manifest and rail shipping paper for three years
* Forwarding at least three copies to the next non-rail transporter or designated facility (if the shipment is delivered by rail), or the last rail transporter designated to handle the waste in the United States.

31. RAIL TO TSDF
For rail delivery to the designated facility, the rail transporter must obtain the dated signature of the owner or operator of the designated facility on the manifest or shipping paper, and retain one copy of the manifest or shipping paper for three years
Rail to TSDF
For rail delivery to the designated facility, the rail transporter must obtain the dated signature of the owner or operator of the designated facility on the manifest or shipping paper, and retain one copy of the manifest or shipping paper for three years.

32. RAIL TO NON-RAIL
For delivery by rail to a non-rail transporter, the rail transporter must obtain the dated signature of the non-rail transporter on the manifest and must retain a copy for at least three years
Since the manifest is not required to accompany the rail shipment, the non-rail transporters might obtain a copy of the manifest directly from the generator
If the hazardous waste is leaving the United States, the transporter must receive an Acknowledgment of Consent from the generator, and ensure that it accompanies the shipment at all times
The Acknowledgment of Consent is consent from the receiving country to accept the shipment
Rail to Non-Rail
For delivery by rail to a non-rail transporter, the rail transporter must obtain the dated signature of the non-rail transporter on the manifest and must retain a copy for at least three years.
Since the manifest is not required to accompany the rail shipment, the non-rail transporters might obtain a copy of the manifest directly from the generator.
If the hazardous waste is leaving the United States, the transporter must receive an Acknowledgment of Consent from the generator, and ensure that it accompanies the shipment at all times.
The Acknowledgment of Consent is consent from the receiving country to accept the shipment.
(Note that this requirement is not specific to rail, but also applies to all other modes of transportation).

33. PIPELINE SHIPMENTS
Transportation of hazardous waste by pipeline does not meet the RCRA definition of transportation
Piping as a mode of transport is not specifically addressed by RCRA, nor is it prohibited
However, hazardous waste piped off-site may be subject to other provisions of RCRA
Pipeline Shipments
Transportation of hazardous waste by pipeline does not meet the RCRA definition of transportation (Section ) and therefore is not subject to Part 263 regulations.
Piping as a mode of transport is not specifically addressed by RCRA, nor is it prohibited. However, hazardous waste piped off-site may be subject to other provisions of RCRA.

34. TRANSFER FACILITIES
A transfer facility is an area used to temporarily store wastes on route to a TSDF
Transfer facilities may be carrier terminals, loading docks, or other areas where waste is kept during the normal course of transportation
Transporters may store manifested shipments of hazardous waste in containers at a transfer facility for 10 days or less without a storage permit under Section
Transfer Facilities
A transfer facility, as defined in 40 CFR Section , is an area used to temporarily store wastes on route to a TSDF.
Transfer facilities may be carrier terminals, loading docks, or other areas where waste is kept during the normal course of transportation (e.g., when drivers change shifts).
Transporters may store manifested shipments of hazardous waste in containers at a transfer facility for 10 days or less without a storage permit under Section

35. TRANSFER FACILITIES
Transfer facilities are not required to operate under RCRA storage permits provided the waste is manifested, kept in DOT specification containers, and stored less than 10 days
There is no specific time limit for a hazardous waste shipment to reach the designated facility.
If a LQG does not receive a signed copy of the manifest from the designated facility within 35 days of the date the initial transporter accepted the waste, the generator must contact the transporter
If a copy of the manifest is not received within 45 days of the date the waste was accepted by the initial transporter, then the LQG must submit an Exception Report to the EPA Regional Administrator
Transfer Facilities
Transfer facilities are not required to operate under RCRA storage permits when the hazardous waste is held during the normal course of transportation and the waste is manifested, kept in DOT specification containers, and stored less than 10 days.
There is no specific time limit for a hazardous waste shipment to reach the designated facility.
If a large quantity generator (LQG) does not receive a signed copy of the manifest from the designated facility within 35 days of the date the initial transporter accepted the waste, the generator must contact the transporter and the owner or operator of the designated facility to determine the status of the waste (Section (a)).
If a copy of the manifest is not received within 45 days of the date the waste was accepted by the initial transporter, then the LQG must submit an Exception Report to the EPA Regional Administrator.
Small quantity generators have reduced reporting requirements under Section (b). The requirements to contact the transporter and to report the discrepancy prevent waste from being held or re-routed unnecessarily during transport.

36. EXPORTING HAZARDOUS WASTE
There are additional requirements for transporters who export hazardous waste
Before waste can be exported to a foreign country, the generator (or primary exporter) must obtain the country's approval for the shipment via an acknowledgment of Consent that is processed by the State Department
The regulations governing exports of hazardous waste are found in Part 262, Subpart E
Exporting Hazardous Waste
There are additional requirements for transporters who export hazardous waste (263.20(g)).
Before waste can be exported to a foreign country, the generator (or primary exporter) must obtain the country's approval for the shipment via an acknowledgment of Consent that is processed by the State Department.
The regulations governing exports of hazardous waste are found in Part 262, Subpart E.

37. TRANSPORTER AS A GENERATOR
Anyone, including a transporter, who imports hazardous waste from a foreign country must comply with the generator requirements, including initiating a manifest
If the transporter mixes wastes with different DOT shipping descriptions by placing them in a single container, the transporter must initiate a new manifest and comply with the generator regulations
The transporter should be named in the generator block and the old manifest(s) should still accompany the waste
Additionally, any other substantial shipping changes would require that a new manifest be prepared
Transporter as a Generator
Under Section , anyone, including a transporter, who imports hazardous waste from a foreign country must comply with the generator requirements, including initiating a manifest.
If the transporter mixes wastes with different DOT shipping descriptions by placing them in a single container (e.g., drum, tank, truck), the transporter must initiate a new manifest and comply with the generator regulations (Section (c)(2)).
The transporter should be named in the generator block and the old manifest(s) should still accompany the waste.
Additionally, any other substantial shipping changes would require that a new manifest be prepared.

38. PERMITS, LICENSES, AND INSURANCE
Transporters do not need RCRA permits if they comply with 40 CFR Part 263
If the transporter stores hazardous waste longer than 10 days or treats or disposes of wastes at their facility, a RCRA permit would be required
In addition, states often require special permits or licenses for transporters
Although EPA does not require transporters to have liability insurance, the Federal Motor Carrier Act, implemented by DOT, does require it
Permits, Licenses, and Insurance
Transporters do not need RCRA permits if they comply with Part However, if the transporter stores hazardous waste longer than 10 days or treats or disposes of wastes at their facility, a RCRA permit would be required.
In addition, states often require special permits or licenses for transporters.
Although EPA does not require transporters to have liability insurance, the Federal Motor Carrier Act, implemented by DOT, does require it (49 CFR Parts 387).

39. EPA/DOT INTERFACE
As part of the RCRA cradle-to-grave waste management system, the transporter regulations ensure proper delivery of the hazardous waste to the designated TSDF
The 40 CFR Part 263 transporter requirements adopted portions of the DOT regulations for the safe transport of DOT classified hazardous materials
The DOT references in the RCRA regulations include requirements for labeling, marking, placarding, and containers, and also outline the DOT requirements for responding to spills or discharges
EPA incorporated these requirements by reference, to ensure consistency with the DOT regulations and to avoid duplicative and burdensome requirements
EPA/DOT Interface
As part of the RCRA cradle-to-grave waste management system, the transporter regulations ensure proper delivery of the hazardous waste to the designated TSDF.
The 40 CFR Part 263 transporter requirements adopted portions of the DOT regulations for the safe transport of DOT classified hazardous materials.
The DOT references in the RCRA regulations include requirements for labeling, marking, placarding, and containers, and also outline the DOT requirements for responding to spills or discharges. EPA incorporated these requirements by reference, to ensure consistency with the DOT regulations and to avoid duplicative and burdensome requirements (see note at Section (a)).

40. TRANSPORTER TRAINING
DOT’s Hazardous Materials Regulations (HMR) include training requirements in several sections for Hazardous Waste Transporters:
GENERAL: 49 CFR 173.1
SPECIFIC: 49 CFR
MODAL: Air 49 CFR ; Vessel 49 CFR ; Highway 49 CFR and
Hazardous Waste Transporter Training
DOT’s hazardous materials transportation law (49 U.S.C. § 5101 et seq.), is the basic statute regulating the transportation of hazardous materials (hazmat) in the United States. This law requires the training of ALL hazmat employees.
The purpose is to increase a hazmat employee's safety awareness and be an essential element in reducing hazmat incidents. The Hazardous Materials regulations (HMR) include training requirements in several sections of Title 49 Code of Federal Regulations (CFR) as follows:
GENERAL: 49 CFR 173.1
SPECIFIC: 49 CFR
MODAL: Air 49 CFR ; Vessel 49 CFR ; Highway 49 CFR and

41. TRANSPORTER TRAINING TRAINING REQUIREMENTS Each hazmat employer must:
train and test,
certify, and
develop and retain records of current training (inclusive of preceding three years) for each hazmat employee (during the period of employment and 90 days thereafter)
TRAINING REQUIREMENTS FOR TRANSPORTERS
The DOT requires that each hazmat employer must: 
train and test,
certify, and
develop and retain records of current training (inclusive of preceding three years) for each hazmat employee (during the period of employment and 90 days thereafter).

42. TRANSPORTER TRAINING Hazmat training must include:
General awareness/familiarization,
Function-specific,
Safety, and
Driver training (for each hazmat employee who will operate a motor vehicle).
Hazmat Training for Transporters
Hazmat training must include: 
General awareness/familiarization,
Function-specific,
Safety, and
Driver training (for each hazmat employee who will operate a motor vehicle).

43. TRANSPORTER TRAINING Initial training
A new employee, or an employee who changes job functions, may perform hazmat job functions before completing training, provided:
- the employee does so under the direct supervision of a properly trained and knowledgeable hazmat employee
- the hazmat training is completed within 90 days of employment or change in job function
Recurrent training
Required at least once every three years
Relevant training received from a previous employer or source may be used to satisfy the requirements
Frequency of training
Initial training
A new employee, or an employee who changes job functions, may perform hazmat job functions before completing training, provided:
- the employee does so under the direct supervision of a properly trained and knowledgeable hazmat employee; and
- the hazmat training is completed within 90 days of employment or change in job function.
Recurrent training
Required at least once every three years. The three year period begins on the actual date of training.
• Relevant training received from a previous employer or source may be used to satisfy the requirements provided a current record of training is obtained from the previous employer or source.

44. TRANSPORTER TRAINING Training Records must include:
Hazmat employee's name;
Completion date of most recent training;
Training Materials (Copy, description, or location);
Name and address of hazmat trainer; and
Certification that the hazmat employee has been trained and tested
Training Records must include: 
Hazmat employee's name;
Completion date of most recent training;
Training Materials (Copy, description, or location);
Name and address of hazmat trainer; and
Certification that the hazmat employee has been trained and tested.

45. RECORDKEEPING
A generator must keep a copy of each manifest 3 years or until he receives a signed copy from the designated facility which received the waste
This signed copy must be retained as a record for at least three years from the date the waste was accepted by the initial transporter
A generator must keep a copy of each Biennial Report and Exception Report for a period of at least three years from the due date of the report
A generator must keep records of any test results, waste analyses, or other determinations made in accordance with 40 CFR for at least three years
Recordkeeping
(a) A generator must keep a copy of each manifest signed in accordance with 40 CFR (a) for three years or until he receives a signed copy from the designated facility which received the waste. This signed copy must be retained as a record for at least three years from the date the waste was accepted by the initial transporter.
(b) A generator must keep a copy of each Biennial Report and Exception Report for a period of at least three years from the due date of the report.
(c) A generator must keep records of any test results, waste analyses, or other determinations made in accordance with 40 CFR for at least three years from the date that the waste was last sent to on-site or off-site treatment, storage, or disposal.
(d) The periods or retention referred to in this section are extended automatically during the course of any unresolved enforcement action regarding the regulated activity or as requested by the EPA Administrator.

46. BIENNIEL REPORT
A generator who ships any hazardous waste off-site to a TSDF within the U.S. must prepare and submit a single copy of a Biennial Report to the Regional EPA Administrator by March 1of each even numbered year
The Biennial Report must include the following information:
(1) The EPA identification number, name, and address of the generator;
(2) The calendar year covered by the report;
(3) The EPA identification number, name, and address for each off-site TSDF;
(4) The name and EPA identification number of each transporter
Biennial Report
(a) A generator who ships any hazardous waste off-site to a treatment, storage or disposal facility within the United States must prepare and submit a single copy of a Biennial Report to the Regional EPA Administrator by March 1of each even numbered year. The Biennial Report must be submitted on EPA Form 8700–13A, must cover generator activities during the previous year, and must include the following information:
(1) The EPA identification number, name, and address of the generator;
(2) The calendar year covered by the report;
(3) The EPA identification number, name, and address for each off-site treatment, storage, or disposal facility in the United States to which waste was shipped during the year;
(4) The name and EPA identification number of each transporter used during the reporting year for shipments to a treatment, storage or disposal facility within the United States;

47. BIENNIEL REPORT
(5) A description, EPA hazardous waste number, DOT hazard class, and quantity of each hazardous waste shipped off-site for shipments to a TSDF
(6) A description of the efforts undertaken to reduce the volume and toxicity of waste generated
(7) A description of the changes in volume and toxicity of waste actually achieved during the year in comparison to previous years
(8) The certification signed by the generator or authorized representative
Any generator who treats, stores, or disposes of hazardous waste on-site must submit a biennial report
Biennial Report continued
(5) A description, EPA hazardous waste number (from 40 CFR part 261, subpart C or D), DOT hazard class, and quantity of each hazardous waste shipped off-site for shipments to a treatment, storage or disposal facility within the United States. This information must be listed by EPA identification number of each such off-site facility to which waste was shipped.
(6) A description of the efforts undertaken during the year to reduce the volume and toxicity of waste generated.
(7) A description of the changes in volume and toxicity of waste actually achieved during the year in comparison to previous years to the extent such information is available for years prior to 1984.
(8) The certification signed by the generator or authorized representative.
(b) Any generator who treats, stores, or disposes of hazardous waste on-site must submit a biennial report covering those wastes in accordance with the provisions of 40 CFR parts 270, 264, 265, and 266. Reporting for exports of hazardous waste is not required on the Bi-ennial Report form. A separate annual report requirement is set forth at 40 CFR

48. EXCEPTION REPORTING
A generator of greater than 1000 kilograms/month who does not receive a copy of the manifest with the handwritten signature of the owner or operator of the TSDF within 35 days of the date the waste was accepted by the initial transporter must contact the transporter and/or the owner or operator of the TSDF
A generator of greater than 1000 kilograms/month must submit an Exception Report to the EPA Regional Administrator if he has not received a copy of the manifest with the handwritten signature of the owner or operator of the designated facility within 45 days of the date the waste was accepted by the initial transporter
Exception Reporting
(a)(1) A generator of greater than 1000 kilograms of hazardous waste in a calendar month who does not receive a copy of the manifest with the handwritten signature of the owner or operator of the designated facility within 35 days of the date the waste was accepted by the initial transporter must contact the transporter and/or the owner or operator of the designated facility to determine the status of the hazardous waste.
(2) A generator of greater than 1000 kilograms of hazardous waste in a calendar month must submit an Exception Report to the EPA Regional Administrator for the Region in which the generator is located if he has not received a copy of the manifest with the handwritten signature of the owner or operator of the designated facility within 45 days of the date the waste was accepted by the initial transporter.

49. EXCEPTION REPORTING The Exception Report must include:
A legible copy of the manifest for which the generator does not have confirmation of delivery;
A cover letter signed by the generator or his authorized representative explaining the efforts taken to locate the hazardous waste
A generator of greater than 100 kilograms but less than 1000 kilograms of hazardous waste/month who does not receive a copy of the manifest within 60 days of the date the waste was accepted by the initial transporter must submit a legible copy of the manifest, with some indication that the generator has not received confirmation of delivery, to the EPA Regional Administrator
Exception Reporting
The Exception Report must include:
(i) A legible copy of the manifest for which the generator does not have confirmation of delivery;
(ii) A cover letter signed by the generator or his authorized representative explaining the efforts taken to locate the hazardous waste and the results of those efforts.
(b) A generator of greater than 100 kilograms but less than 1000 kilograms of hazardous waste in a calendar month who does not receive a copy of the manifest with the handwritten signature of the owner or operator of the designated facility within 60 days of the date the waste was accepted by the initial transporter must submit a legible copy of the manifest, with some indication that the generator has not received confirmation of delivery, to the EPA Regional Administrator for the Region in which the generator is located.

50. RECOMMENDED INSPECTION ITEMS
Determine if the facility transports hazardous waste off-site by using their own vehicles or a contractor
Verify that the transporter has an EPA identification number
Verify that all waste accepted, transported, or offered for transport is accompanied by a manifest
Verify that prior to transport, the transporter signs and dates the manifest and returns a copy to the generator prior to leaving the facility
Verify that the transporter retains a copy of the manifest after delivery
Recommended Inspection Items
Determine if the facility transports hazardous waste off-site by using their own vehicles or a contractor.
Verify that the transporter has an EPA identification number.
Verify that all waste accepted, transported, or offered for transport is accompanied by a manifest.
Verify that prior to transport, the transporter signs and dates the manifest and returns a copy to the generator prior to leaving the facility.
Verify that the transporter retains a copy of the manifest after delivery.

51. RECOMMENDED INSPECTION ITEMS
Verify that all wastes accepted by the transporter are delivered to the designated facility listed on the manifest, or the alternate designated facility if an emergency prevents delivery, or the next designated transporter or the place outside the United States designated by the generator
Verify that manifests are kept on file for three years
Recommended Inspection Items continued
Verify that all wastes accepted by the transporter are delivered to the designated facility listed on the manifest, or the alternate designated facility if an emergency prevents delivery, or the next designated transporter or the place outside the United States designated by the generator.
(NOTE: If the transporter cannot deliver the hazardous waste to the facilities or transporters designated on the manifest, the transporter must contact the generator for further directions and revise the manifest according to the generator's instructions.)
Verify that manifests are kept on file for three years.
(NOTE: Special issues involved in the transportation of hazardous waste by air, rail or water are not addressed in this guide.)

52. RECOMMENDED INSPECTION ITEMS
Determine what pre-transport procedures for hazardous waste are used
Inspect a sample of containers awaiting transport to verify that containers are properly constructed and exhibit no leaks, corrosion, or bulges
Examine end-seams for minor weeping that indicates drum failure
Verify that labeling and marking on each container is compatible with the manifests
Recommended Inspection Items continued
Determine what pretransport procedures for hazardous waste are used.
Inspect a sample of containers awaiting transport to verify that containers are properly constructed and exhibit no leaks, corrosion, or bulges.
Examine end-seams for minor weeping that indicates drum failure.
Verify that labeling and marking on each container is compatible with the manifests.

53. RECOMMENDED INSPECTION ITEMS
Verify that the following information is displayed on a random sample of containers of 110 gal. ( L) or less in accordance with 49 CFR :
“HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.”
- Generator's name and address
- Manifest Document Number ____ .
Verify that proper DOT placarding is available for the transporter
Recommended Inspection Items continued
Verify that the following information is displayed on a random sample of containers of 110 gal. ( L) or less in accordance with 49 CFR :
- “HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.”
- Generator's name and address
- Manifest Document Number ____ .
Verify that proper DOT placarding is available for the transporter.

54. RECOMMENDED INSPECTION ITEMS
Verify that transport operators have instructions to notify local authorities and take clean-up action so that the discharge does not present a hazard
Verify that transporters give notice to the National Response Center and report in writing as required by 49 CFR and 49 CFR
Recommended Inspection Items continued
Verify that transport operators have instructions to notify local authorities and take clean-up action so that the discharge does not present a hazard.
Verify that transporters give notice to the NRC and report in writing as required by 49 CFR and 49 CFR

55. RECOMMENDED INSPECTION ITEMS
Determine if the facility has a transfer facility.
If so, verify the following:
- Transfer facility storage is for 10 days or less
- DOT packaging requirements are met
- Shipments are manifested and manifests accompany shipments
- Storage is consistent with good management practices
Verify that transporters do not store manifested shipments of land disposal restricted wastes for more than 10 days
Recommended Inspection Items continued
Determine if the facility has a transfer facility.
If so, verify the following:
- Transfer facility storage is for 10 days or less
- DOT packaging requirements are met
- Shipments are manifested and manifests accompany shipments
- Storage is consistent with good management practices.
(NOTE: Storage for more than 10 days will require a TSDF permit.)
Verify that transporters do not store manifested shipments of land disposal restricted wastes for more than 10 days (40 CFR (a)(3)).

56. TIPS FOR USING CONTRACTORS
Remember, You Control Your Facility or Area!
Review Procedures With Them Before Starting the Job!
Ensure They Are Properly Trained!
Determine Their Environmental Compliance Record!
Determine Who Is in Charge of Their People!
Determine How They Will Affect Your Facility’s Environmental Compliance!
Remember, You Control Your Facility or Area! Do not let contractors violate the law on your property. Take time to review procedures with them before they begin the job. Ensure they are properly trained and know how to follow your businesses Best Management Practices.
Before you hire them, investigate their environmental compliance record. Enforcement agencies normally will disclose violators. Before the job begins, find out who is in charge and hold them accountable for maintaining environmental compliance. Before any job begins, determine how the work will affect your facility’s environmental compliance! 88
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57. ELEMENTS OF A SUCCESSFUL HAZARDOUS WASTE TRANSPORTATION PROGRAM
DETAILED WRITTEN HAZARDOUS WASTE TRANSPORTATION INSPECTION GUIDELINES.
2. DETAILED WRITTEN HAZARDOUS WASTE TRANSPORTATION BEST MANAGEMENT PRACTICES.
3. EXTENSIVE EMPLOYEE TRAINING PROGRAMS
4. PERIODIC REINFORCEMENT OF TRAINING
5. SUFFICIENT DISCIPLINE REGARDING IMPLEMENTATION
6. PERIODIC FOLLOW-UP
A Successful Hazardous Waste Transportation Program takes work. A successful program incorporates these elements:
DETAILED WRITTEN HAZARDOUS WASTE TRANSPORTATION INSPECTION GUIDELINES.
2. DETAILED WRITTEN HAZARDOUS WASTE TRANSPORTATION BEST MANAGEMENT PRACTICES.
3. EXTENSIVE EMPLOYEE TRAINING PROGRAMS
4. PERIODIC REINFORCEMENT OF TRAINING
5. SUFFICIENT DISCIPLINE REGARDING IMPLEMENTATION
6. PERIODIC FOLLOW-UP 89
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58. THE IMPORTANCE OF A CLEAN ENVIRONMENT
“I would ask all of us to remember that protecting our environment is about protecting where we live and how we live. Let us join together to protect our health, our economy, and our communities -- so all of us and our children and our grandchildren can enjoy a healthy and a prosperous life.”
In closing, it is important to remember the words of Carol Browner, EPA Administrator during the Clinton Administration. She said:
“I would ask all of us to remember that protecting our environment is about protecting where we live and how we live. Let us join together to protect our health, our economy, and our communities -- so all of us and our children and our grandchildren can enjoy a healthy and a prosperous life.”
Carol Browner Former EPA Administrator 90 84
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