On February 24, EPA alerted hazardous waste stakeholders about paper hazardous waste Manifests in circulation that were produced by a non-EPA approved printer.
Manifests with a manifest tracking number (MTN) within the following range should not be used for hazardous waste shipments:
FLE to 14066222
If your facility has or has experienced an issue submitting a manifest in this MTN range, EPA advises you to sign on to RCRAInfo
to provide feedback.EPA sent the notice to professionals subscribed to the electronic Manifest (e-manifest) e-mail list. .
EPA believes the “vast majority” of these Manifests have now been removed from circulation.
Related: How EPA Plans to Increase e-Manifest Use
Who Can Print the Hazardous Waste Manifest?
The Resource Conservation and Recovery Act (RCRA) hazardous waste regulations strictly prohibit persons from printing Manifests without EPA approval (40 CFR 262.21(a)(1)).
Hazardous waste shippers can obtain and use Manifests from any source “so long as the source of the printed form has received approval from EPA to print the manifest…” 40 CFR 262.21(g) lists potential registered sources for Manifests as state agencies, commercial printers, generators, transporters, TSDFs, and hazardous waste brokers.
EPA issues a unique three-letter manifest tracking number suffix to each approved printer of the manifest. The printer must then use the suffix to pre-print a unique MTN on each Manifest.
Training to Sign the Manifest
When you sign the hazardous waste Manifest, you certify that your waste is in compliance with all aspects of US DOT's Hazardous Materials Regulations (HMR) in 49 CFR Parts 100–181. To adequately prepare employees for this responsibility, comprehensive DOT hazmat training must be provided.
The Hazmat & Waste Ground Shipper Certification provides comprehensive hazmat training required at 49 CFR 172.704 and will help satisfy DOT's initial or recurrent training mandates for employees who prepare and offer shipments of hazardous materials (including hazardous waste).
DOT requires recurrent hazmat training once every 3 years (49 CFR 172.704).