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Our Comprehensive FAQ library is designed to help you navigate waste disposal, treatment and handling
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Manifest and Documentation

What are the differences between manifests and bills of lading?

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.

What are MSDS Sheets?

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.

Where do I get MSDS Sheets?

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.

How long am I required to keep hazardous waste manifests for?

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.)

Do I need a Generator’s EPA Identification Number?

An EPA idnetification 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.

What is a Waste Analysis Plan?

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.

What is an EPA Hazardous Waste Profile?

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.

Chemical Waste

Lab Packing
Treatment
Definitions

Universal Waste
Waste Categorization
Storage and Accumulation
Definitions
Industrial Waste

Transport and Disposal
Storage and Accumulation
Compliance
Definitions

Document Destruction

Compliance
Transport and Disposal

Medical Waste

Sharps Collection
Waste Categorization
Packaging
Storage
Transport and Disposal
Treatment
Compliance
Definitions

Pathological Waste

Waste Categorization
Treatment
Definitions

Pharmaceutical Waste

Waste Categorization
Definitions