EPA final rule modifies hazardous waste manifest
Apr 1, 2005 12:00 PM
The Environmental Protection Agency published a final rule March 4, 2005, modifying the hazardous waste manifest, which is used as the Department of Transportation proper shipping paper when transporting hazardous wastes.
Revisions are intended to standardize the content and appearance of the manifest form and continuation sheet (Forms 8700-22 and 8700-22a). This is accomplished by eliminating nine of the 11 “optional data fields” that may have been required by individual states. The EPA decided to retain the optional RCRA waste codes (Item I) and the handling codes (Item K); however, to ensure a standardized form, these data fields are now mandatory.
Some of the changes the EPA enacted include:
Removal of the state manifest tracking number — Since there will no longer be separate state versions of the manifest form, state manifest tracking numbers are unnecessary by the new mandatory requirement for manifest tracking numbers to be pre-printed on the forms by a registered printer.
Removal of the state transporter ID fields (Items C and E) — The transportation company's EPA ID number is still included on the form.
Removal of the transporter's phone fields (Items D and F) — not necessary since the revised form includes an emergency response phone number field.
Removal of the state facility ID field (Item G) — state ID number is duplicated information since the EPA ID number is included in Item 10.
Consolidation of special handling fields (Item J) — Item J is removed, but the information is now required in Item 15.
Revisions to the continuation sheet, which is used when more than two transporters transport waste, mirror the revisions to the manifest. For example, there are no longer fields for state transporter ID numbers or phone numbers; blocks for a manifest document number or state manifest number have been replaced by a block requiring a unique, pre-printed tracking number.
- Several new data elements were enacted:
Inclusion of the generator's site address in addition to its mailing address.
Inclusion of a space to incorporate the DOT-required emergency response telephone number; however, in instances of consolidated loads where there are multiple emergency response numbers, these numbers should appear immediately after the shipping descriptions under Item 9b (See 49CFR172.604(a)(3).
Inclusion of a new international shipments data field.
In its proposed rule, the EPA requested comments on the implementation of an electronic manifest system. The EPA received numerous comments that “merit further analysis” before implementing the electronic manifest. As a result, the EPA has decided to delay its decision on implementing the e-manifest option while continuing to move forward with other revisions to the manifest
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