Search

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 Lion.com in Fall 2020

How well do you know EPA’s RCRA Generator Improvements?

Get up to date when Lion presents live, instructor-led RCRA Refresher training that covers the major changes EPA made and drives home the real-world impacts on your facility. Join us live on September 1, September 17, September 29, October 6, and October 20.

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

Find a Post

Compliance Archives

Lion - Quotes

This training broke down the regulations in an easy-to-understand manner and made them less overwhelming. I now feel I have the knowledge to make more informed decisions.

Amanda Oswald

Shipping Professional

Lion's online training is more comprehensive, has better slides, and is a superior training experience than what I would get from other trainers.

Robert Brenner

District Environmental Manager

Our instructor was very dynamic and kept everyone's interest. Hazmat shipping can be a dry, complicated topic but I was engaged the entire time.

Kimberly Arnao

Senior Director of EH&S

Energetic/enthusiastic! Made training enjoyable, understandable and fun!

Amanda Walsh

Hazardous Waste Professional

My experience with Lion training, both online and in the classroom, is that they are far better organized and provide a better sequential explanation of the material.

Robert Roose

Manager, Dangerous Goods Transportation

I really enjoyed this training. Even after years on both sides of the comprehension coin, I find myself still learning! The quality of the delivery exceeded much of the training I have received in the past.

Neil Ozonur

Safety Officer

I used the IT support number available and my issue was resolved within a few minutes. I don't see anything that could have made it better.

Danny Province

EHS Professional

I like Lion's workshops the best because they really dig into the information you need to have when you leave the workshop.

Tom Bush, Jr.

EHS Manager

Convenient; I can train when I want, where I want.

Barry Cook

Hazmat Shipping Professional

One of the best trainings I have ever received!

Brandon Morfin

EH&S Manager

Download Our Latest Whitepaper

Look beyond the annual "Top 10 List" to see specifics about the most cited OSHA health & safety Standards and the individual regulations that tripped up employers the most last year. 

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.