How to Sign the Hazardous Waste Manifest During COVID-19

Posted on 8/25/2020 by Lauren Scott and Roger Marks

[UPDATE 12/01/20]
EPA's temporary policy regarding how to sign paper hazardous waste manifests during COVID-19 terminated on November 30, 2020. 
Many handlers of hazardous waste have reached out to EPA with concerns about maintaining proper social distancing while attempting to obtain the generator’s signature on the hazardous waste manifest.

On August 20, EPA announced updated guidance to assist generators, transporters, and designated facilities with signing the hazardous waste manifest amid the coronavirus pandemic.

In the memo, Statement About Signing Paper Hazardous Waste Manifests During the COVID-19 Public Health Emergency, EPA recognizes the challenges handlers of hazardous waste grapple with when they must sign the manifest while maintaining safe social distancing.

The August 20 memo makes slight revisions to the Temporary COVID-19 Manifest Signature Policy EPA released in May.

The following recommendations are for transporters who need to obtain the generator’s signature but cannot certify compliance with applicable pre-transportation requirements. EPA already allows transporters who can certify compliance with pre-transportation requirements (i.e., proper packaging, marks, labels, etc.) to sign the Manifest in lieu of the generator as an offeror of the shipment.  

EPA’s first suggestion for transporters who must obtain a generator signature on the Manifest is to use the new electronic manifest (e-Manifest) to do so. How to obtain an e-Manifest account.

When the using the e-Manifest is not feasible, transporters should follow these steps:
  1. Write the name of the generator in Box 15 and, under “Signature,” write “COVID-19 signature substitute,” (or abbreviate to “COVID-19 sig. sub.”);
  2. The generator should provide a signature substitute in an alternative communication (such as text message, email, or hard copy letter) to the transporter and designated facility; and
  3. The transporter or designated facility write in Box 14 of the manifest “documentation for generator signature substitute available upon request.”
Generators and transporters taking these steps should maintain this documentation for three years from the last shipment need a signature substitute.

These revised COVID-19 policy for hazardous waste manifests will remain in effect until November 30, 2020.  Latest updates from EPA.

Live RCRA Refresher Training at in Fall 2020

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Need initial RCRA training for new employees? The RCRA Hazardous Waste Management online course guides hazardous waste personnel through the RCRA hazardous waste management requirements to properly manage hazardous waste from cradle-to-grave. 

Tags: COVID-19, hazardous waste management, hazardous waste manifest, shipping hazardous waste

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