Who Can Sign Hazardous Waste Generators?
Accurately checking and signing hazardous waste manifests are highly important tasks that every generator must undertake. By signing a manifest, you are asserting that a waste stream has been appropriately tested, coded, and labeled for shipping. Failure to sign appropriately could lead to hefty environmental fines and a possible prison sentence.
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Identification
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Hazardous wastes are termed "hazardous" if they meet certain criteria as outlined by the Environmental Protection Agency (EPA) and the Department of Transportation (DOT). According to the Healthcare Environmental Resource Center (HERC), there are six steps that should be followed to determine if a waste is hazardous. These steps are outlined in detail on the EPA and HERC websites.
Hazardous Waste Manifests
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Hazardous waste manifests are forms used by generators when they have hazardous waste that needs to by taken offsite to various Treatment, Storage, and Disposal (TSD) facilities. Manifests are important because they provide an official chain of custody for a waste, tracking it from its point of generation, through the various transporters and ultimately to the TSD facility. You can find an example of a Uniform Hazardous Waste Manifest on the EPA website.
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Signing a Manifest
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All generators must have at least one environmental technician or specialist who has completed the appropriate training necessary to sign hazardous waste manifests. This training must comply with 40 CFR 262.34 and includes a detailed look into the laws governing hazardous waste, hazardous waste determination, labeling requirements and filling out manifests. The training must adequately satisfy EPA specifications and may be completed in a traditional classroom or online.
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