If you’re in an industry where you generate waste, it’s imperative that you know exactly how to properly, legally, and safely deal with that waste. A big part of that issue involves correct shipping methods. If you’re creating and shipping waste, be aware of the terms “manifest” and “bill of lading.” You’ll need to know the differences, when they’re used, and how to properly complete the appropriate forms.

01   /  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.

Every state also stipulates certain requirements and both need to be followed. For example,

Georgia’s Environmental Protection Department publishes guidelines regarding fees and substance reporting fees which can be downloaded from that website. Additional details regarding existing laws and proposed rules regarding solid waste management and waste control laws are also available.

It is the responsibility of all hazardous or biological medical waste generators to be aware of various aspects of hazardous waste management not only within the state’s environmental rules and those of the state of Georgia’s Department of Natural Resources, but also those of the Official Code of Georgia Annotated (O.C.G.A.) rules, which include:

    • Department of Natural Resources 391-3-11 Hazardous Waste Management
    • OCGA 12-8-60 Georgia Hazardous Waste Management Act
    • OCGA 12-8-90 Georgia Hazardous Site Response Act
    • OCGA 12-8-140 Mitigating Effect of Hazardous Materials Discharge

A manifest contains relevant information about the specific hazardous or biological materials being transported (class of hazardous material, how much is being transported, etc.), emergency contact numbers, the generator’s EPA identification number (if applicable), and much more. For additional information and/or clarification, you can also refer to the Georgia Environmental Compliance Assistance Program (GECAP) regarding hazardous waste and recycling guidelines, manuals, codes, and so forth.

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.

Some of the components of a bill of lading is typically provided by the carrier on pick-up and is often attached to the freight. It can include information regarding the shipper, where the waste is going, special instructions, the date of the pick-up, a description of the materials as well as weight, type of containers, drums, or other packaging. It must also have the Department of Transportation hazardous material designation, which must be clearly cited. It is the responsibility of the waste generator to ensure that appropriate requirements are met and are applicable to shipping or transportation.

These two documents are used in very different situations, so it’s important for safety and legal reasons that each be used in the correct scenario.

02   /   Are These Documents Interchangeable?

While a manifest and a bill of lading are used in the movement of materials from one area to another, they are not the same and cannot be used interchangeably. If you have hazardous materials, you are required to use a hazardous waste manifest. The same is applicable to biological or biological/hazardous waste.

It’s rare that hazardous waste would be shipped without any paperwork. That said, there are occasions when the paperwork is not properly filled out. You must:

    • Provide the correct emergency response number
    • Ensure that the appropriate parties sign the paperwork
    • Identify the class of hazardous waste being transported

Other requirements often include the generator’s information, the manifest tracking number, transporter information, U.S. DOT description (per Code of Federal Regulations – CFR 49, Part 172), number of containers, and so forth.

03   /   Importance of accurate paperwork!

While you may think of paperwork as extraneous and nothing more than annoying bureaucratic steps in the shipping process, a manifest or a bill of lading is an essential component in the safe transport of materials. This is especially true when it comes to hazardous materials. In such cases, the manifest will contain information that alerts and determines appropriate measures for first responders to take in the event of an accident or spill.

Specific materials require various handling and treatment methods, such as those that are flammable, corrosive, or reactive. Such information provides instruction in use of personal protective gear or whether you can put water on the spilled materials and so forth.

Therefore, a properly filled out hazardous waste manifest will identify the materials and codes  (which are numeric) to ensure fast and appropriate responses to not only quickly remedy an accident or spill situation, but also minimize environmental damage and keep people as safe as possible.

04   /   Georgia rules regarding transfer of biomedical (hazardous) waste

Be aware of certain regulations depending on the type of waste being transported. For example, when it comes to transfer of biomedical waste off-site, the regulations of the state of Georgia (Rule 391-3-4-.15) specify that the generator of biomedical waste (a) “shall transfer custody of the waste only to a collector who was operating under authority of these rules.”

Another section (b) specifies that “biomedical waste shall not be transported in the same vehicle with other solid waste unless the biomedical waste is contained in a separate, fully enclosed leak-proof container within the vehicle compartment or unless all of the waste is to be treated as biomedical waste in accordance with the requirements of these rules.”

A number of additional rules are applicable including permit by rule for collection, transportation, processing, and disposal (Rule 391-3-4-.06) and rules for measuring and reporting requirements (Rule 391-3-4-.17).

It is a responsibility of the waste generator to know and understand these rules. Rules and regulations of the state of Georgia can be found here. Don’t guess. Know the laws to avoid possible fines and penalties as well as damage to reputation.

05   /   Turn to the professionals for paperwork compliance

Penalties for non-compliance can be severe. If in doubt, seek professional help such as that provided by MCF Environmental Services. We’ll make sure you’re filling out manifests and bills of lading correctly. Protect your employees, the environment, and the general public

Remember – it is your responsibility to ensure that your paperwork is accurate. Liability falls to the generator if there are mistakes, so reaching out to a professional is often best for every party involved. If you would like to have your staff trained and accredited on DOT handling, reach out to our support team for information on our online OSHA training, we would be happy to partner with getting your team up to speed on the latest compliance!

For more information about all relevant paperwork and other proper packing and shipping protocols, please contact a representative of MCF Environmental Services, one of the most experienced hazardous and medical waste management companies with national service.

Thank you for reading our blog!

Robert Losurdo

President, COO