The Manifest

The Uniform Hazardous Waste Manifest is the key to the cradle-to-grave management system (Figure 11.10.3). Using the manifest, generators and regulators can track the movement of hazardous waste from the point of generation to the point of ultimate treatment, storage, or disposal (TSD).

The HSWA requires manifests to certify that generators have programs in place to reduce waste volume and tox-icity to the degree the generator determines economically practicable. In addition, the treatment, storage, or disposal method chosen by the generator must be the best method currently available to minimize risks to human health and the environment.

Generators must prepare manifests properly since they are responsible for the production and ultimate disposition of hazardous wastes. Some common mistakes found on manifests are (Turner 1992):

Omission of the 24-hr emergency response telephone number. As of December 31, 1990, the DOT required inclusion of a 24-hr telephone number for use if an incident should occur during transportation. Shippers and carriers should look closely at this section to ensure its proper completion. Omission of the manifest document number. Many generators use this control number to indicate the number of shipments made during a specified period. Others use it to indicate shipments from a specific section of their facility.

Misunderstanding of the generator name and mailing address. The address listed should be the location managing the return manifest form. The 12-digit EPA identification number is site specific in that it is assigned to the physical location where the hazardous waste is generated.

Improper entry of shipping name, hazard class or UN/NA numbers. 49 CFR Sec. 172.202 specifies the proper order for entering a basic description on a shipping document. The technical or chemical group names may be entered in parentheses between the proper shipping name and hazard class.

The manifest is part of a controlled tracking system. Each time waste is transferred from a transporter to a designated facility or to another transporter, the manifest must be signed to acknowledge receipt of the waste. A copy of the manifest is retained by each link in the transportation chain. Once the waste is delivered to the designated facility, the owner or operator of the facility must send a copy of the manifest back to the generator. This system ensures that the generator has documentation that the hazardous waste has reached its destination.

The multiple-copy manifest is initially completed and signed by the hazardous waste generator. The generator retains Part 6 of the manifest, sends Part 5 to the EPA or the appropriate state agency, and provides the remainder to the transporter. The transporter retains Part 4 of the manifest and gives the remaining parts to the TSD facility upon arrival. The TSD facility retains Part 3 and sends Parts 1 and 2 to the generator and the regulatory agency, or agencies, respectively. Throughout this transition, the hazardous waste shipment is gener-

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