Hazardous waste shipping

Scope

EPA’s “pre-shipping” regulations for hazardous waste require generators to properly package, mark and label, placard, and manifest shipments of hazardous waste.

Regulatory citations

• 40 CFR 262 Subpart B — Manifest requirements applicable to small and large quantity generators
• 40 CFR 262 Subpart C – Pre-shipping requirements for generators
• 40 CFR 262.40 — Recordkeeping
• 40 CFR 262.42 — Exception reporting
• 40 CFR 263 Subpart B — Requirements for transporters
• 40 CFR 264/265 Subpart(s) E — Manifest system, recordkeeping, and reporting for receiving facilities

Key definitions

• Bulk packagings: Packagings in which hazardous materials are loaded with no intermediate form of containment and which have:
  • A maximum capacity greater than 119 gallons (450 L) as a receptacle for a liquid;
  • A maximum net mass greater than 882 pounds (400 kg) and a maximum capacity greater than 119 gallons (450 L), as a receptacle for a solid; or
  • A water capacity greater than 1,000 pounds (454 kg), as a receptacle for a gas. (A Large Packaging in which hazardous materials are loaded with an intermediate form of containment, such as one or more articles or inner packagings, is also a bulk packaging.)
• Combination packaging: One or more inner packagings secured in a non-bulk outer packaging. It does not include a composite packaging.
• Composite packaging: An outer packaging and an inner receptacle forming one integral packaging. Once assembled it remains an integrated single unit.
• Contact person: A person who is knowledgeable about the waste being shipped and accepts responsibility for answering questions about it in an emergency. A person listed as a contact must be reachable 24-hours per day while the waste is being shipped.
• Continuation sheet: An optional additional page for the manifest if the generator needs more room to accurately fill out the manifest. (Form 8700-22A)
• Designated facility (also called the receiving facility): The treatment, storage, and disposal facility that received the hazardous waste from the generator. These facilities may be approved to receive hazardous wastes or they may be approved for state-specific wastes only.
• Electronic manifest system (e-Manifest): A system of software applications and centralized EPA database to track waste shipments electronically. Generators may still elect to use paper copies of the manifest.
• Exception reporting: The generator has not received a signed copy of the manifest back from the receiving facility. LQGs that do not receive a copy from the receiving facility within 35 days must attempt to contact the facility. If that doesn’t resolve the problem, they must file an Exception Report with the state. SQGs that do not receive a signed copy of the manifest from the receiving facility within 60 days must send a copy of the manifest to EPA or their state with a note stating they did not receive confirmation of delivery.
• Hazardous waste generator: The facility that generates (produces) a hazardous waste. There are three distinct hazardous waste categories:
  • Very small quantity generators (VSQGs) are minimally regulated.
  • Small quantity generators (SQGs) must comply with basic hazardous waste management regulations.
  • Large quantity generators (LQGs) are highly regulated.
• Hazardous waste transporter: The company used to ship waste from the generator to the final destination. The transporter must meet all state and federal EPA and DOT hazardous materials requirements and obtain an EPA ID number.
• Intermediate bulk container or IBC: A rigid or flexible portable packaging, other than a cylinder or portable tank, which is designed for mechanical handling.
• Management method codes: The codes used to describe the type of hazardous waste management system used to treat, recover, or dispose of a hazardous waste. These codes are entered on the manifest by the receiving facility.
• Overpack: An enclosure that is used by a single consignor to provide protection or convenience in handling of a package or to consolidate two or more packages.
• Packaging: A receptacle and any other components or materials necessary for the receptacle to perform its containment function in conformance with the minimum packing requirements.
• Packing group: An indication of the degree of danger presented by a hazardous material.
• RCRAInfo: The website linked to the e-Manifest system.
• Uniform Hazardous Waste Manifest: The formal name for the hazardous waste manifest, EPA Form 8700-22.
• Waste codes: The number assigned to a particular type of hazardous waste (e.g., D001 for corrosive waste). Some states have waste codes assigned to state-only wastes.
• Waste minimization: The statement found on the hazardous waste manifest certifying that the waste generator has developed and is following a plan to reduce the amount of waste generated.

Summary of requirements

Hazardous waste generators must:

• Ship hazardous waste off-site within the time limits assigned to their generator category.
• Mark and label containers of hazardous waste according to DOT’s requirements.
• Prepare packages of hazardous waste for shipment according to DOT’s requirements.
• Provide the correct placards to the waste transporter.
• Complete and sign the hazardous waste manifest for shipping hazardous waste.

Transporters of hazardous waste must:

• Ensure they have an EPA ID number and the proper credentials for transporting hazardous waste.
• Use a manifest properly and maintain all proper shipping records.
• Contain and cleanup any spills or discharges while the hazardous waste is in their possession.

• Accept or reject loads of hazardous waste.
• Notify generators of rejected loads.
• Send a copy of completed paper manifests to the generator.
• Submit completed manifests electronically to EPA or send paper copies to EPA.
• Submit fee payment to EPA upon receipt of monthly invoice.