Paints & Coatings Resource Center

Plain Language Guide to Regulations
Solid/Hazardous Waste Management

Shipping Wastes Off-Site

When shipping waste off site, SQGs and LQGs must follow certain procedures that are designed to ensure safe transport and proper management of the waste.
  • Package, label, and mark your shipment, and placard the vehicle in which your waste is shipped as specified in DOT regulations.
  • Prepare a hazardous waste manifest to accompany your shipment.
  • Include a notice and certification with each waste shipment.
  • Ensure the proper management of any hazardous waste you ship (even when it is no longer in your possession).
Selecting a TSDF
SQGs and LQGs may send their waste only to a regulated TSDF or recycler. Most regulated TSDFs and recyclers will have a permit from the state or EPA. Some, however, may operate under other regulations that do not require a permit. Check with the appropriate state authorities to be sure the facility you select has any necessary permits. All TSDFs and recyclers must have EPA identification numbers.

Labeling Waste Shipments
SQGs and LQGs must properly package, label, and mark all hazardous waste shipments, and placard the vehicles in which these wastes are shipped following Department of Transportation (DOT) regulations. Most small businesses use a commercial transporter to ship hazardous waste. These transporters can advise you on specific requirements for placarding, labeling, marking, and packaging; however, you remain responsible for compliance. For additional information, consult the DOT regulations (49 CFR Parts 172 and 173), or call the DOT hazardous materials information line at 202 366-4488.

Federal regulations allow you to transport your own hazardous waste to a designated TSDF provided that you comply with DOT rules. Some states, however, do not allow this practice. Call DOT and your state hazardous waste management agency regarding applicable regulations.

Selecting a Transporter or TSDF/Recycler
It is important to choose your transporter and your TSDF carefully since you remain responsible for the proper management of your hazardous waste even after it has left your site.

For help in choosing a transporter or TSDF, check with the following sources:

  • References from business colleagues who have used a specific hazardous waste transporter or TSDF.
  • Trade associations for your industry that might keep a file on companies that handle hazardous waste.
  • The Better Business Bureau or Chamber of Commerce in the TSDF's area, which might have a record of any complaints registered against a transporter or a facility.
  • Your state hazardous waste management agency or EPA Regional office, which can tell you whether the transporter or TSDF has a U.S. EPA identification number and a permit, if required.
Preparing Hazardous Waste Manifests
A hazardous waste manifest must accompany all hazardous waste that is shipped off site. A hazardous waste manifest is a multipart form designed to track hazardous waste from generation to disposal. It will help you to track your waste during shipment and make sure it arrives at the proper destination. If you send waste to a recycling facility, you may be able to use a tolling agreement instead of a manifest. A tolling agreement is a "closed-loop" arrangement whereby a generator contracts with a recycling company to reclaim its hazardous waste and return it as a recycled product, thereby avoiding disposal. A copy of the contract must be kept on file for three years after the contract has ended.

Various versions of hazardous waste manifest forms are available. Some states require their own manifest form. If the state to which you are shipping your waste requires its own manifest, use that states form. To obtain manifest forms, contact the hazardous waste management agency of the recipient state, your transporter, or the TSDF that you intend to use. If the state to which you are shipping your waste does not have its own manifest, but the state in which your waste was generated does require its own manifest, use your states form. To obtain blank forms, contact your transporter or your state hazardous waste agency. If neither state requires a manifest, you can use the federal Uniform Hazardous Waste Manifest, EPA Form 8700-22. Copies are available from some transporters, TSDFs, and some commercial printers. Your state hazardous waste agency can refer you to manifest suppliers.

You must fill in all parts of a manifest. Information requested includes: name of transporter, name of the designated facility, your EPA ID number, and a description of the waste based on DOT requirements, such as proper shipping name and hazard class. Call the DOT information line for more information on DOT waste description requirements.

The transporter signs the completed manifest when the shipment is accepted for transport. The facility operator at the designated TSDF also signs the form when the shipment is received and sends a copy of it back to you. You must keep this copy on file for three years. (It might be a good practice, however, to keep it for as long as you are in business.)

Any SQG that does not receive a signed copy of the manifest from the designated TSDF within 60 days of shipment must submit a legible copy of the manifest to the state or EPA regional office. This copy, known as an exception report, simply indicates that a signed copy was not received from the facility operator.

Treating Your Waste to Meet the Land Disposal Restrictions (LDRs)
Most hazardous wastes may not be land disposed unless they meet "treatment standards. "The Land Disposal Restrictions (LDR) program requires that the waste is treated to reduce the hazardous constituents to levels set by EPA, or that the waste is treated using a specific technology. It is your responsibility to ensure that your waste is treated to meet LDR treatment standards before it is land disposed. (See below for a description of required LDR notices.) Most SQGs probably will have their designated TSDF do this treatment. If you choose to treat your waste yourself to meet LDR treatment standards, there are additional requirements including waste analysis plans, notifications, and certifications. To learn about these requirements call the RCRA Hotline, your state agency, or EPA Regional office, and consult 40 CFR Part 268.

Regardless of where the waste is being sent, for each shipment of waste subject to LDRs you must send the receiving TSDF or recycler an LDR notice. This notice must provide information about your waste, such as the EPA hazardous waste code and the LDR treatment standard. The purpose of this notice is to let the TSDF know that the waste must meet treatment standards before it is land disposed. There is no required form for this notice, but your TSDF may provide a form for you to use. A certification may also be required in specific situations. Call the RCRA Hotline, your state agency, or EPA regional office and consult 40 CFR Part 268 for help with LDR notification and certification requirements.

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