If the answer to this question is yes, then there are several items that need to be taken into account, specifically with regards to the uniform hazardous waste manifest. The purpose of the Hazardous Waste Manifest is to track hazardous waste from the generator site until it reaches the facility where it will be stored, treated or disposed of. The Uniform Hazardous Waste Manifest is a form that is required by the Environmental Protection Agency (EPA) and the Department of Transportation (DOT) for all generators, regardless of their generator status, who transport hazardous waste to an off-site facility for recycling, storage, treatment or disposal.
The waste manifest is a single form containing multiple copies. The form contains information regarding descriptions and volumes of the waste that is handled and the treatment or disposal requirements. In addition, the manifest contains signatures of all parties that were required to handle the waste. Each person who signs the manifest is required to retain a copy of the manifest for their records. Once the waste is received by the destination facility, a representative signs the manifest and returns the signed manifest to the generator, which affirms that the waste has been received.
Unfortunately, there are specific training requirements for employees who sign the hazardous waste manifest that are often overlooked. Training requirements are defined by the Federal Resource Conservation and Recovery Act (RCRA) Subtitle C and DOT regulations. Depending on your generator status there are various requirements for training under RCRA regulations. These training requirements are defined in 40 CFR Part 261 or Part 265.
As a hazardous waste generator you are also considered a “shipper” of hazardous materials under DOT’s hazardous materials transportation regulations. Specific requirements for hazardous materials employees can be found in 49 CFR Part 172, Subpart H. This training must be conducted within 90 days of employment and renewed every three years.
By signing the hazardous waste manifest, the employee is stating that they are trained on the aforementioned requirements. The employee signing the manifest is also verifying that all hazardous materials being transported are properly packaged, labeled, classified, and in proper condition to be transported according to 49 CFR Part 172.204. The signor of the manifest can now be held personally liable for compliance.
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