Before shipping hazardous waste to an offsite facility for treatment, storage, or disposal, a generator must comply with numerous pre-transport requirements. These requirements include obtaining an EPA Identification number, preparing a Uniform Hazardous Waste Manifest (EPA Form 8700-22), and complying with several Department of Transportation (DOT) requirements.
EPA Identification (ID) Number
A generator must obtain an EPA ID number before treating, storing, disposing, or transporting (or offering for transport) hazardous waste. EPA ID numbers are site-specific numbers assigned to generators, transporters, and treatment, storage, or disposal facilities, and need only be obtained once.
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What is an EPA ID number verification questionnaire?
An EPA ID number verification questionnaire is sent to every generator of hazardous to verify EPA ID Number information. Every generator must return this questionnaire back to DTSC in order for their EPA ID number to remain active.
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Manifest EPA Form 8700-22)
Generally, a generator who transports, or offers for transportation, hazardous waste for off-site treatment, storage, or disposal must prepare a Uniform Hazardous Waste Manifest. The manifest is a multiple-copy tracking document for hazardous waste shipments that is required by DOT and DTSC. The manifest tracks the chain of custody for the waste from the point it leaves the generator to final disposition at a hazardous waste TSDF or a recycling facility. Each party that manages the waste signs the manifest and retains a copy, providing critical continuity between the generator and the receiving facility. Once the chain is complete, the receiving facility returns a signed copy of the manifest to the generator. If a generator does not receive a copy of the manifest signed by the designated facility owner or operator within 45 days of the date the waste was accepted by the initial transporter (60 days for a SQG), he or she must file an exception report (§66262.42).
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What is consolidated manifesting?
Consolidated manifesting, formerly known as modified manifesting or milkrunning, allows certain registered hazardous waste transporters to combine specified wastes from multiple eligible generators on a single manifest, rather than using a separate manifest from each generator.
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The Chapter 12 manifesting requirements do not apply to "on-site" transportation of hazardous waste. "On-site" is defined in §66260.10 as:
According to §66262.20, a generator must designate one facility on the manifest that is permitted to handle the waste described on the manifest. A designated facility, as defined in §66260.10, is a federally or state-permitted treatment, storage, or disposal facility, a recycling facility as regulated pursuant regulated under chapter 16 of T22, has received a permit, a grant of interim status, or a variance to operate without a permit or grant of interim status from the Department, or is otherwise authorized by law to receive specific hazardous wastes.
The generator may also designate an alternate facility in case the transporter cannot deliver the waste to the primary designated facility. If the transporter is unable to deliver the shipment to either facility on the manifest, the generator must designate a third facility.
DOT requires that generators of hazardous waste subject to manifesting meet several requirements before transporting or offering hazardous waste for transport off site, including packaging (§66262.30), labeling (§66262.31), marking (§66262.32), and placarding (§66262.33). The DOT regulations are found in 49 CFR Parts 172 through 179