If you're a generator of hazardous materials, it's imperative you're completely familiar with the proper protocol surrounding the EPA's hazardous waste manifest. This matters for a number of reasons, ranging from general safety concerns to saving yourself from unnecessary fines.
Hazardous Waste Manifest: What You Need to Know
Hazardous Waste Manifests Are Required by the EPA
The first crucial reason you need to pay attention to the manifest is simple: it's federally required by the Environmental Protection Agency (EPA) and Department of Transportation (DOT). Without fail, every shipment of hazardous material must be accompanied by this vital piece of paperwork.
For many years, these manifests were state specific. That meant every state's manifest could be different than another state's, and all of those could be different than the EPA's version. This caused a lot of potential confusion and led to the standardization of this form. Now every generator of hazardous waste uses the same manifest with the same information.
Failing to provide this paperwork at all or handling this form incorrectly can lead to fines and other repercussions by these federal regulatory bodies.
Be Prepared for a Hazardous Waste Audit
If you do ever get audited by the EPA or a state government agency regarding your hazardous waste transport protocol, you need to have proper records of all these manifests. They are your documentation and proof you've been shipping your generated waste correctly and within the timeframe required by your EPA generator status.
Remember, if you're a large quantity generator, you will have to ship out your hazardous waste every ninety days—no exceptions—and your paperwork can prove you're fully complying with those laws.
If you go into an audit without the proper documentation, one of two things is going to happen. One, after much time and hassle, you'll eventually be able to track down copies of your manifests, or two, you won't be able to secure those documents and will have no way of verifying your compliance. Best-case scenario, you've wasted a lot of unnecessary time. Worst-case scenario, you get hit with some serious and costly fines.
Even if you never end up getting audited, it's always better to be safe than sorry when it comes to federal compliance!
Safety Issues: Make Sure You're Filling Out Your Hazardous Waste Manifests Correctly
As with most paperwork, it's not enough to simply have it. You need to also be doing it correctly. This is especially vital for the transporter and receiving facility of the waste. If your transporters don't accurately know what they are transporting, this quickly leads to extremely dangerous situations. Materials that aren't meant to be in close physical proximity could end up next to each other the truck. Improper and dangerous protocol could also be used if there was an accident. If, for example, they're transporting reactive waste and first responders try to use water or something else that waste reacts negatively to, this puts people at very serious risk.
The same goes for the receiving facility. For all the same imperative safety reasons, they absolutely must know what kind of waste they are accepting into their facility.
A manifest will include this relevant emergency information and could quite literally save lives during emergency situations.
Looking to the Future: E-Manifests
As this paperwork process continues to evolve and improve over the years, the next stage that generators are looking toward is the e-manifest. While the documentation today is still physical paper, it's slowly moving in the direction of electronic paperwork. These e-manifests look to make things much easier and more streamlined. It will also make keeping track of those records exponentially easier as well.
This can benefit everyone in the hazardous waste disposal process: the generator, the transporter, the facility receiving the waste, and the EPA. Eventually electronic records could even apply to other forms, such as the certificate of destruction.
For more information about transporting hazardous waste or the necessary paperwork that accompanies that process, please feel free to reach out to a representative of MCF Environmental Services, an Atlanta waste management company.