If you're looking into waste management companies to assist with the disposal of your generated waste, it's imperative you confirm all their employees are trained and qualified to handle the associated paperwork. In particular, that means they must be trained and legally qualified to fill out either a shipping manifest or a bill of lading—depending on the contents of the particular waste shipment.
Don't Let Unqualified Employees Fill Out Your Hazardous Waste Manifests and Bills of Lading!
Bill of Lading (BOL) Training
The training requirements for bills of lading are much less stringent than they are for manifests. This is obviously because the materials transported on a BOL are less hazardous or potentially dangerous than those transported on a manifest. A BOL is for the following waste types:
- Nonhazardous waste.
- Biohazardous material.
- Universal waste (lightbulbs, batteries, ballasts, and so on).
However, just because waste shipped on a BOL is less dangerous than waste shipped on a manifest doesn't mean it should be thrown in the standard trash or not handled to the letter of the local, state, and federal laws. To that end, every employee who fills out or deals with this piece of paperwork should have the proper DOT training.
Hazardous Waste Manifest Training
Because hazardous materials pose more of an overt threat, the training required to handle manifests is more intense than that needed for BOLs. To sign manifests, you must go through a comprehensive training related to specific Department of Transportation requirements—most notably 49 CFR 172.204 and 172.205.
The person actually signing the manifest if the last line of defense before that shipment goes on the road, so to confidently sign off, he or she must have function-specific training in everything from classification and naming to packaging and labeling.
Proper Training Helps Ensure Environmental Safety
This kind of paperwork is in place because the items within the waste shipment have been deemed unsafe for the standard trash. Even something going out on a BOL could have small amounts of mercury (or other RCRA metals), so there are serious and specific reasons to specially transport and dispose of the shipment.
Failure to vet your waste management company could mean you're working with unqualified employees who don't properly fill out their paperwork—all of which could lead to environmental contamination.
Proper Training Helps Ensure Your Financial Safety
Failure to comply with EPA regulations can mean big fines for your company, and remember, you are ultimately responsible for anything and everything that happens with your waste. Even if you contract out with a company, and it's the company that makes the mistakes, those fines can still circle back and hit you. So, in addition to environmental safety, working with a qualified, trained, experienced, reputable company could actually save you money in avoided fines.
Having your shipping manifests and bills of lading filled out accurately every time (and receiving copies of that paperwork every time) means you know exactly what was sent out, whether that was biohazardous materials or hazardous waste, and you can prove to any examining body during an audit that you have been doing everything right. Again, this helps you avoid sizeable fines.
At the most elementary level, this training also means you'd be qualified to look at the paperwork and assess whether your vendor was billing your properly, according to what type of waste you're shipping and how much.
Training: It's Not Just for Your Waste Management Company
Anybody involved in this paperwork process should be properly trained. That means generators and transporters alike should both be educated about how to properly and accurately handle all waste shipment paperwork.
If, at any point, somebody simply signs off without checking (and without knowing what problems to look for) that could quickly lead to dangerous, costly mistakes.
While training is only required for the people actually dealing with the paperwork, it certainly wouldn't hurt to have somebody come onsite and train everybody at your facility at once. This would qualify everyone to check that any given shipment meets all necessary requirements, meaning everything is properly labeled, lids are correctly and safely adhered, the right container is used, everything meets all DOT requirements, and so on.
Failure during any one of these steps could lead to a notice of violation for the company or a citation on the driver's license.
For more information about what you should be looking for in hazardous waste management companies or how to ensure their employees are properly filling out your paperwork, feel free to reach out to a representative of MCF Environmental Services today, an Atlanta waste management company.