Hazardous Waste Generators regardless of generator status are breathing a sigh of relief that 2023 is not a reporting year for submitting the Biennial Hazardous Waste Report. However, it’s always an excellent time to check that you’re using the best reporting practices possible.
Federal regulations require generators and transporters of hazardous waste and owners or operators of hazardous waste treatment, storage, or disposal facilities to use the uniform hazardous waste manifest.
What is the Hazardous Waste Manifest Form?
These forms from the EPA will contain information about the type and quantity of waste generated, information about transportation, and signatures of all parties involved in moving the waste.
The EPA Enforces The Rules
The Hazardous Waste Manifest Form, EPA Form 8700-22, can appear a bit overwhelming at first, especially if you need to transport the waste on the interstate. For transportation needs, you’ll also need to fill out the continuation EPA Form 8700-22A for travel.
Avoidable Fines and Fees
1. Keep it in the Box
The EPA actually charges a $25 fine for unreadable items manifest forms. These charges add up if you haven’t been documenting things correctly. If you’re filling in the forms by hand, messy handwriting can cost you per occurrence.
2. Check Your EPA ID
If you completed your biennial report the way you were supposed to, your ID should still be active. An expired ID is the sign that there are a number of problems with your reporting.
3. Exceptions to the Rule
Special Care for Small Quantity Generators (SQGs) and Very Small Quantity Generators (VSQGs) must be taken into account as they are not required to submit biennial reports, but may need to review other state-specific requirements.
It’s important that these generators check their EPA ID number regularly to ensure they are still registered correctly.
4. Mismatched Waste Codes
Misidentifying hazardous waste could be an unintentional error, but one small misstep might bring along a lot of bureaucratic scrutiny.
- Triple check that the waste manifest codes used are correct
- Label and track all hazardous waste with the correct code
5. Other Inaccuracies
In addition to checking your waste codes, there are a number of other ways to be hit with another $25 fine.
Double Check the Following:
- Make sure you’re using the correct units of measurement. Where the form asks for gallons, you must report in gallons instead of pounds.
- Check that you’re using the correct number when listing total weights. Do not use decimals or fractions.
How Long Do You Have to Keep Hazardous Waste Manifest Forms?
The shipper of the hazardous waste is required to retain a copy or an electronic image of the manifest for 375 days, but the shipper must also later hold onto a copy of the hazardous waste manifest for 3 years, which includes their copy and the copy from the disposal facility designating that the waste has been disposed of properly.
Accurate for the EPA
This system exists to accurately control the hazardous waste at your facility. Many waste generators prefer to outsource their filing, moving, and reporting to a trusted hazardous waste transportation company to avoid these types of mistakes and small errors that could cost quite a lot in fees.
To ensure that your generator status remains the same and your company follows all of the outlined guidelines, considering hiring a company that works full time in hazardous waste management across the country.
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