Hazardous Waste — Manifests and Documentation

In the field of hazardous waste management, a waste manifest is a piece of paperwork required by the federal Environmental Protection Agency (EPA) and the Department of Transportation (DOT) in order to legally transport hazardous waste materials.

A bill of lading, on the other hand, is used to transport other materials such as biomedical waste. This waste is also known as regulated waste, regulated medical waste, or even red bag waste. These documents can also be used to transport empty containers or containers or boxes of documents for destruction. Essentially, a bill of lading in this industry is simply paperwork that often accompanies waste that is not deemed hazardous.

MSDS stands for Material Safety Data sheets; paperwork that essentially identifies the type of chemical you’re using and how to safely handle that chemical. It can include information such as:

• The exact chemical constituents of the material.
• The proper protocol if spilled.
• The proper protocol if that chemical is ingested, gets in one’s eyes, or gets on one’s skin.
• Whether the chemical constitutes hazardous material.
• The concentration of the chemicals.
• Proper waste disposal methods for that product.

An MSDS (or, now, SDS - Safety Data Sheet) comes directly from the manufacturer of that product. If you need to secure materials safety data sheets for the products you’re using, one approach is to contact the manufacturer directly.

A hazardous waste manifest must accompany all hazardous waste that is shipped off site. Designed as a multipart form, a hazardous waste manifest is designed to track hazardous waste from generation to disposal (i.e. from when it leaves your facility to the point it arrives at its intended destination)

You must retain hazardous waste manifests for three years. In addition, the following records must also be retained for that timeframe:

• All notices and documentation associated with Land Disposal Restrictions
• Biennial Reports
• Exception Reports
• Any test results, waste analyzes, or similar information related to the waste shipped off-site
• Your inspection schedule and reports. (Specific inspection requirements are found in 40 CFR 265.15.)

An EPA identification number is only applicable if you're generating hazardous waste, furthermore it depends on the following criteria:

• Your location (specifically what state or district)
• Whether the waste is hazardous or not
• How much of the hazardous material needs to be shipped

It is only If you generate less than 220 pounds per month of hazardous materials, that your facility is considered a conditionally exempt small quantity waste generator, and you don’t need an EPA ID number. If you generate over 2,200 pounds of hazardous waste every month, you are a large quantity generator and (like small quantity generators that accumulate in excess of 220 pounds), you need an EPA ID number to legally ship that waste irrespective of what state your business is based in.

A business requires an RCRA permit if it generates, treats, or stores hazardous materials or is involved with hazardous waste removal. Applying for this permit requires you to create a Waste Analysis Plan (WAP). A Waste Analysis Plan is essentially a step-by-step guide for treating, storing, and disposing hazardous wastes including corrosives, flammables, explosives, gasses, poisons, etc. In developing the guide, you need to outline by what methods you determined the materials to be hazardous, how you defined its specific nature and how you determined that the hazardous material must be handled.

Whoever designs your Waste Analysis Plan must be trained in RCRA regulatory requirements and highly knowledgeable about waste characterization and hazardous waste disposal.

A Hazardous Waste Profile, formerly known as a “waste characterization profile,” requires you to list all chemical properties of the particular type of waste you intend to dispose of or transport. The hazardous waste profile must be presented to the treatment & disposal facility prior to its arrival, otherwise it’s illegal for the disposal facility to accept receipt of your hazardous waste.