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A different kind of training.


Two Agencies That Regulate the
Transportation of Hazardous Waste


Hazardous Waste Regulations
Iowa: Illinois:
US EPA Region VII IEPA


Interstate & Intrastate Transportation
Regulations
Iowa Illinois


More About…
US Department of US Environmental
Transportation Protection Agency
• Regulates the • Regulates hazardous
transportation of waste from Cradle to
hazardous materials Grave.
in commerce. • Cradle = Point of
• Hazardous material = generation.
HazMat = hazardous • to = Transportation.
waste from most • Grave = Final
hazardous waste treatment and
generators. disposal.


“Most hazardous waste generators…?”
• US DOT defines a hazardous waste @ 49 CFR
171.8 as any material that requires a manifest.
• A Conditionally Exempt Small Quantity Generator
(CESQG) is not required to use the Uniform
Hazardous Waste Manifest.
• Therefore the hazardous waste generated by a
CESQG is not a hazardous waste per the US
DOT.
• It may still be a hazardous material based on its
potential hazards.


What is Your Hazardous Waste
Generator Status?

• Large Quantity • Take the survey, or
Generator. review the…
• Small Quantity • Hazardous Waste
Generator. Generator Summary
• Conditionally Exempt Chart.
Small Quantity
Generator.


1. Identify Your Hazardous
Waste Generator Status.


On-Site Storage Requirements
• Container in good
condition.
• Container compatible with
waste.
• Separate incompatible
materials.
• No waste on outside of
container.
• Closed except when
adding or removing waste.
• Weekly inspections.


On-Site Labeling Requirements

• “Hazardous Waste”
while on-site.
• Date of
accumulation at 1st
point hazardous
waste goes in drum.
4/26/12
• Unless satellite
accumulation
area.


2. Comply with US EPA
Regulations for On-Site
Storage of Hazardous
Waste.


Off-Site Shipment Requirements:
• Container must meet US
EPA and US DOT
requirements prior to off-
site shipment.
1. Closed and sealed.
2. Labeled & marked.
3. Clean and in good
condition.
4. UN performance
oriented packaging.


Container Closure Requirements of DOT
• US EPA regulations reference US DOT for
packaging closure.
• US DOT requires shipper to…
1. Apply closure consistent with manufacturer‟s
closure instructions.
2. Maintain copy of manufacturer‟s notification
and closure instructions unless permanently
affixed to packaging.


3. Obtain and Maintain
Container Manufacturer
Notification and Closure
Instructions.


The Hazardous Waste Label
• The hazardous waste
label fulfills US EPA
requirements and the
XYZ, LLC
234 Happy Lane
marking requirements of
Freeport, IL 61032 DOT.
Paint Related
Material, UN1
263


More on the Hazardous Waste Label
• “Hazardous Waste.”
• “Federal Law
Prohibits…”
• Generator's name and
address.
• Generator‟s EPA ID #.
4/26/12
• Manifest tracking
number.
• DOT Shipping
information.


HazMat Labels for Hazardous Waste
• Label must be near
proper shipping name
marking.
• If more than 1
label, must be within 6”
of each other.
• Refer to DOT Chart 14
for more information
about markings and
labels.


Condition of the Container
• Container in good
condition.
• No waste on outside of
container.
• Container compatible
with waste.
• Separate incompatible
materials.


4. Ensure Container in
Proper Condition for
Transportation.

@DanielsTraining 21

UN Performance Oriented Packaging

• A packaging construction system based on UN
recommendations for non-bulk packages.
• Packages/containers must have some form of this
certification for use with hazardous waste.
• Guide to Performance Packaging Codes.


5. Use the Correct UN
Performance Oriented
Packaging for Your
Hazardous Waste.


The Uniform Hazardous Waste Manifest

• Required by both US
EPA & US DOT.
• Tracks HW from
generator‟s site to final
disposal.
• “Uniform” since 9.5.06.
• Required for PCB‟s
since 1989.


The Manifest in Illinois

• Required for Special
Waste & Used Oil.
• Must mail a copy of
the manifest to IEPA
within 48 hours of
signing for
hazardous waste.
• Non-Haz/Special
Waste Report for out-
of-state shipments.


6. Comply with State
Specific Requirements.


Information for the Manifest
• Generator name, address, phone #, US EPA ID #.
• Transporter name & US EPA ID #.
• Designated facility name, address, phone #, US EPA
ID #.
• US DOT Proper Shipping Description.
• Hazardous waste codes, up to six (6).
• Emergency response information.
• Emergency response phone #.
• US EPA website: Manifests for more information.


The Proper Shipping Description
• Basic description – in order:
1. Identification number UN 1263
2. Proper shipping name Paint Related Material
3. Hazard class 3
4. Packing group II
• Additional description.
• Total quantity.
• Number and type of
packaging used.

@DanielsTraining 28

The Basic Description
• Information can be found in the Hazardous
Materials Table @ 49 CFR 172.101.
• Add “Waste” to the beginning of the proper
shipping name if shipping hazardous waste.


What is Emergency Information?
Emergency Response Emergency Response
Information Telephone Number
• Purpose is to provide • Purpose is to provide
information so 1st responders with
carriers and 1st „immediate access‟ to
responders may a person
respond to hazardous knowledgeable about
material incidents in the hazards and
transportation. characteristics of the
hazardous material in
transportation.


What is Emergency Information?
Emergency Response Emergency Response
Information Telephone Number

815.222.3434


7a. Ensure the driver has
the emergency response
information.
7b. Confirm the Emergency
Response Telephone
Number is Correct.


Signatures on the Manifest
1. Generator/Offeror.
2. Transporter 1.
1 copy left with
Generator/Offeror.
Remaining copies go
with transporter 1.
3. Transporter 2 (if
necessary).
4. Designated facility.
Copy returned to
Generator.


You and the Shipper‟s Certification
• Doesn’t have to be authorized representative of
generator, can be…
• Employee, vendor, etc.
• Should have “direct knowledge” of the
information on the manifest.
• Shipment must comply with all regulations. „Best
effort‟ is not enough.
• EPA did not intend to impose personal liability on
the person signing the manifest.


The Shipper‟s Certification on the
Uniform Hazardous Waste Manifest
“I hereby declare that the contents of this
consignment are fully and accurately
described above by the proper shipping
name, and are
classified, packaged, marked and
labeled/placarded, and are in all respects
in proper condition for transport according
to applicable international and national
governmental regulations.”


The Waste Minimization Certification
Large Quantity Generator Small Quantity Generator
40 CFR 262.27(a) 40 CFR 262.27(b)
“I am a large quantity “I am a small quantity
generator. I have a generator. I have
program in place to reduce made a good faith
the volume and toxicity of effort to minimize my
waste generated to the
waste generation and
degree I have determined
to be economically
select the best waste
practicable and I have management method
selected the practicable that is available to me
method of and that I can afford.”
treatment, storage, or
disposal…”


7. Comply With 40 CFR
262.27(a) or (b) as
Applicable.


Generator Notification Requirements
• Contact primary transporter
or TSDF to determine status
of hazardous waste if no
signed copy of HW manifest
w/i 35 days of signing.
• Submit Exception Report to
State or Regional EPA if no
signed copy of HW manifest
w/i 45 days for LQG or 60
days for SQG.


8. Set a Reminder to
Contact Your Transporter
or TSDF Within 30 Days of
Signing the Manifest.


Land Disposal Restrictions
• Applies to LQG &
SQG hazardous
waste only.
• Established treatment
standards for some
hazardous waste prior
to land disposal.


Generator Responsibility for the LDR:
• Determine applicable LDR‟s - if any - for their
hazardous waste. This can be done by…
• Testing.
• Generator knowledge.
• Provide signed LDR, or certification it is not
necessary, to TSDF with initial shipment of waste.
• Signed by authorized representative.
• Maintain signed copy of LDR.
• Update only if changes to waste.


9. Confirm Submittal of
LDR to TSDF and Maintain
Copy for File.


Treatment Storage & Disposal Facilities

• Remember generator‟s „Cradle to Grave‟
responsibility.
• Limit number of TSDF‟s = limited liability.
• Keep records (manifests, etc.) of all waste
shipments for lifetime of facility.
• Regulatory retention period is three (3)
years.
• Audit TSDF‟s.


10. Create an Audit
Schedule for all TSDF‟s
(not just hazardous waste).


For More Information
Illinois Iowa
• How do I manage my • US EPA: Hazardous
Hazardous Waste? Waste Generators.
• How do I manage used • US EPA: Hazardous
rags/absorbants? Waste Manifests.
• IEPA Small Business
Hotline.


This Any
concludes my Questions?
presentation:
The
Regulatory
Requirements
for Off-Site
Shipments of
Hazardous
Waste.
Contact me to Daniels Training Services
815.821.1550
learn more. www.DanielsTraining.com
Info@DanielsTraining.com

Off Site Shipments of Hazardous Waste

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