OFF-SITE TRANSPORTATION OF HAZARDOUS WASTE The applicable regulatory requirements of the US DOT, US EPA, Iowa DNR, and Illinois EPA. And ten (10) things to ensure compliance you must do today. @DanielsTraining Off-Site Transportation of Hazardous Waste 1
A presentation I gave at the 2012 Iowa-Illinois Safety Council Professional Development Conference. It contains an introduction to the two regulatory agencies (EPA & DOT), an overview of on-site management requirements, and an explanation of the the EPA & DOT regulations pertaining to the off site shipment of hazardous waste.
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OFF-SITE TRANSPORTATION OF HAZARDOUS WASTEThe applicable regulatory requirements of the US DOT, US EPA, Iowa DNR, and Illinois EPA.
And ten (10) things to ensure compliance you must do today.
Off-Site Transportation of Hazardous Waste
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PRESENTED BY:
Daniels Training Services815.821.1550www.DanielsTraining.comInfo@DanielsTraining.com
• 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.
• Purpose is to provide information so carriers and 1st responders may respond to hazardous material incidents in transportation.
Emergency Response Telephone Number
• Purpose is to provide 1st responders with ‘immediate access’ to a person knowledgeable about the hazards and characteristics of the hazardous material in transportation.
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What is Emergency Information?Emergency Response
InformationEmergency Response
Telephone Number
815.222.3434
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7a. Ensure the driver has the emergency response information.7b. Confirm the Emergency Response Telephone Number is Correct.
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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.
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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.
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The Shipper’s Certification on theUniform 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.”
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The Waste Minimization CertificationLarge Quantity Generator
40 CFR 262.27(a)“I am a large quantity generator. I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically practicable and I have selected the practicable method of treatment, storage, or disposal…”
Small Quantity Generator
40 CFR 262.27(b)“I am a small quantity generator. I have made a good faith effort to minimize my waste generation and select the best waste management method that is available to me and that I can afford.”
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7. Comply With 40 CFR 262.27(a) or (b) as Applicable.
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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.
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8. Set a Reminder to Contact Your Transporter or TSDF Within 30 Days of Signing the Manifest.
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Land Disposal Restrictions
• Applies to LQG & SQG hazardous waste only.
• Established treatment standards for some hazardous waste prior to land disposal.
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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.
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9. Confirm Submittal of LDR to TSDF and Maintain Copy for File.
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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.
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10. Create an Audit Schedule for all TSDF’s (not just hazardous waste).