Who can sign the manifest?

• An employee who signs the manifest must be trained, at the minimum, every three years.
• Hazardous waste employees must be trained within six months after the date of hire or assignment to the facility, or when they are moved to a new position at the facility.

The person who fills out and signs the manifest needs training in both hazardous waste and hazardous materials (hazmat). That’s because the Department of Transportation (DOT) considers the person who signs the manifest to be a “hazmat employee”. To sign a hazardous waste manifest, the employee must know how the waste was produced and managed, along with the hazardous characteristics of the waste.

A hazmat employee, according to 49 CFR 171.8, is: “an individual employed on a full time., part time, or temporary basis by a hazmat employer, or who is self-employed, who during the course of employment:

• Loads, unloads, or handles hazardous materials;
• Designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs, or tests a package, container, or packaging component that is represented, marked, certified, or sold as qualified for use in transporting hazardous material in commerce;
• Prepares hazardous materials for transportation;
• Is responsible for safety of transporting hazardous materials;
• Operates a vehicle used to transport hazardous materials.”

An employee who signs the manifest must be trained, at the minimum, every three years, according to the requirements of 49 CFR 172.704. Function-specific training is required. Therefore, the more involved in managing, packaging, and shipping the employee is, the more training the employee will need.

As far as the Environmental Protection Agency (EPA) is concerned, when an employee signs the manifest, that means the employee is familiar with the process used to identify, store, and prepare the waste for transport. They must be trained in those areas at a minimum.

The minimal amount of training that small quantity generators (SQGs) must provide is found at 40 CFR 262.16(b)(9)(iii): “The small quantity generator must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies.”

The training requirements for large quantity generators (LQGs) at 262.17(a)(7) are more extensive than for SQGs, but they also require facility-specific training geared toward the particular job of the employee.

Facility personnel must successfully complete a program of classroom instruction, online training (e.g., computer-based or electronic), or on-the-job training that teaches them to perform their duties in a way that ensures compliance with this part. The large quantity generator must ensure that this program includes all the elements described in the document required under paragraph (a)(7)(iv) of this section [which describe emergency procedures and equipment].

Hazardous waste employees must be trained within six months after the date of hire or assignment to the facility, or when they are moved to a new position at the facility. Employees must not work unsupervised until they have completed the training. Facilities must offer refresher training every year.