December 10, 2020: Part II – Preparing Hazardous Waste for Offsite Shipping

You may recall from last month’s newsletter article that a Resource Conservation and Recovery Act (RCRA) hazardous waste requiring the use of the Uniform Hazardous Waste Manifest for offsite shipping is automatically regulated as a DOT Hazardous Waste (which is included in the definition of a Hazardous Material). In essence, this means the preparation of packages and shipping papers are going to be dually regulated by the DOT hazmat regulations and the EPA.

Packaging
The standard DOT rules for assembling, filling, and closing a package apply to hazardous waste. The packages must meet the DOT’s general packaging requirements in 49 CFR Part 173, subpart B. Each package used for the shipment of hazardous materials must be designed, constructed, maintained, filled, its contents so limited, and closed so that it withstands the rigors of normal transportation.

The DOT requires hazard labels, the proper shipping name, the material’s UN identification number, and the name and address of either the shipper or consignee on fully regulated non-bulk packages. Additional markings may be appropriate. For example, if a reportable quantity or more of a hazardous substance (identified in Appendix A of 49 CFR 172.101) is contained in a single non-bulk package, the shipper must communicate that fact with the letters “RQ” marked on the package. All RCRA hazardous wastes are on the list of hazardous substances with RQs ranging from 1 to 5,000 lbs. Orientation arrows are required whenever a combination package contains liquids. (Bulk packages are placarded, and UN identification numbers are displayed.)

The EPA requires additional markings for non-bulk packages. They must be marked with the:
• Generator’s name and address;
• Generator’s EPA identification number;
• Manifest tracking number; and with few exceptions the
• EPA hazardous waste numbers (i.e., waste codes).

The EPA also requires the following statement on non-bulk containers:
“HAZARDOUS WASTE—Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.”

Shipping Papers
The DOT requires a shipping paper containing specific information to accompany most hazmat shipments. At a minimum, these elements are 1) a basic description, 2) number and type of containers, and 3) total quantity of material.
Although the DOT does not have a standardized shipping paper for ordinary hazardous materials, in the case of hazardous waste, the shipper must use the Uniform Hazardous Waste Manifest. The manifest requires the use of special codes for units of measure and types of containers. See last week’s article for a discussion on the DOT’s rules for naming hazardous waste.
There is a protocol for handling each copy of the manifest as well as managing the tracking system. The EPA also specifies retention and exception reporting requirements.
When a representative of the hazardous waste generator signs the manifest, they are not just handing over custody of the material. Only fully trained hazmat and hazardous waste employees may sign the manifest. Do you and your employees know what your signatures in Item #15 really certifies?

What can STARS do for you?
STARS can help you and your employees learn how to prepare your hazardous waste packages and shipping papers for offsite shipping with our new “Storing & Shipping Hazardous Waste” course. The training can be delivered in person, live online, or pre-recorded online. For more info please send an email to info@starshazmat.com or call toll free at (844) 88-STARS or local (352) 200-5017.