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Waste shipping requirements for hazardous waste generators
  • Hazardous waste generators must properly package, label, and mark all hazardous waste shipments, and placard the vehicles used for shipping the wastes following the DOT hazardous materials regulations.
  • Generators must ship hazardous waste offsite within the time limits assigned to their generator category.

The Environmental Protection Agency (EPA) requires hazardous waste generators to properly package, label, and mark all hazardous waste shipments, placard the vehicles used for shipping the wastes following the Department of Transportation’s (DOT) hazardous materials regulations, and ship the waste using the uniform hazardous waste manifest.

DOT’s Hazardous Materials Regulations apply to all private, common, and contract carriers transporting hazardous materials in commerce. The regulations are prescribed to minimize the dangers to life and property related to the transportation of the hazardous materials.

Federal regulations allow a facility to transport their own hazardous waste to a designated treatment, storage, and disposal facility (TSDF) provided that the facility follows all of DOT’s rules. Note that some states do not allow this practice.

Regulatory citations related to waste shipping include:

Summary of requirements:

  • Generators must ship hazardous waste offsite within the time limits assigned to their generator category.
  • Generators must mark and label containers of hazardous waste according to DOT’s requirements.
  • Generators must prepare packages of hazardous waste for shipment according to DOT’s requirements.
  • Generators must provide the correct placards to the waste transporter.
  • Generators must complete and sign the hazardous waste manifest for shipping hazardous waste.
  • Transporters must ensure they have an EPA ID number and the proper credentials for transporting hazardous waste.
  • Transporters must use a manifest properly and maintain all proper shipping records.
  • Transporters must contain and cleanup any spills or discharges while the hazardous waste is in their possession.
  • Receiving facilities must accept or reject loads of hazardous waste.
  • Receiving facilities must notify generators of rejected loads.
  • Receiving facilities must send a copy of completed paper manifests to the generator.
  • Receiving facilities must submit completed manifests electronically to EPA or send paper copies to EPA.
  • Receiving facilities must submit fee payment to EPA upon receipt of monthly invoice.

EPA’s pre-transport requirements at 40 CFR 262 Subpart C apply to small and large quantity generators (SQGs and LQGs); however, very small quantity generators (VSQGs) should also be aware of them. Some states require VSQGs to manifest their waste and many hazardous waste transporters will not accept a waste shipment without a manifest.