Manifest Requirements

One of the primary goals of hazardous waste regulation is to ensure that hazardous wastes are strictly monitored and tracked from the point of generation through ultimate disposal. The tool used to track hazardous waste is a shipping document called a hazardous waste manifest. Hazardous wastes may not be shipped off-site without a manifest and each manifest serves as a legal document. A single manifest typically consists of 8 copies, each designated for specific destinations. This distribution of copies ensures that all parties involved (i.e. generator, transporter, waste facility (TSDF), and the Massachusetts Department of Environmental Protection (DEP) receive matching copies confirming the proper transport and disposition of hazardous waste.

This policy provides guidance on how to correctly complete and manage a hazardous waste manifest. It is important that hazardous waste shipments be coordinated with the Environmental Health and Safety Office (EH&S) office to ensure that Bridgewater State College complies with all manifesting requirements including the technical information content, the distribution system and the recordkeeping/reporting standards. All manifests are to be reviewed by EH&S prior to shipment and copies 6, 7, and 8 must be transferred to EH&S immediately after shipment for the following reasons:

• To ensure the technical and administrative information is accurate and complete
• To ensure that the manifest distribution requirements are met
• To ensure that the manifest recordkeeping/reporting requirements are met
• EH&S serves as a technical contact for transportation-related emergencies which involve hazardous waste. The manifest serves as an immediate identifier for waste characteristics, potential incompatibilities, quantities, etc. in the event of a serious accident involving the shipment.

Definitions and Scope

Massachusetts DEP Regulation 310 CMR 30.000 "Hazardous Waste Management" regulates the hazardous waste manifest. A hazardous waste manifest is an 8-part shipping paper, which must accompany all off-site shipments of hazardous waste. The following format presents the key manifesting requirements. A manifest is used when Bridgewater State College offers hazardous waste for transportation to off-site waste facilities. A manifest may also be used to transport non-hazardous wastes in some special cases. Most states have their own version of a manifest.

A manifest requires substantial technical information and should only be completed by specially trained individuals. EH&S personnel are trained in EPA/DEP/DOT regulations required to ensure that manifests are accurately and completely filled out. Please make every effort to involve EH&S with manifest preparation and review. Never complete a manifest unless you are familiar with all of the EPA/DEP/DOT requirements. Manifest may be obtained from the EH&S office or the waste hauler may supply the manifest. For waste shipments of hazardous waste destined for state other than Massachusetts, special manifests may be needed. Contact EH&S for assistance in these instances.

After filling out the informational sections of the manifest in accordance with the above requirements, manifest copies are distributed among the generator (Bridgewater State College), transporter, disposal facility (TSDF), the destination state's environmental regulatory agency and the DEP to ensure for the tracking of the shipment. In summary, Massachusetts’s manifest distribution is conducted as follows:

Bridgewater State College (Generator) retains copies 6, 7, and 8 and a signed copy of the land disposal restriction (LDR) notification/certification. Copies 6, 7, 8 must be immediately transferred to EH&S since certain copies must be mailed to the Massachusetts DEP within 10 days of shipment. The Transporter (waste hauler) retains copies 1, 2, 3, 4, and 5 with the shipment. Upon arrival with the shipment at the TSDF, the transporter submits copies 1, 2, 3 and 4 to the TSDF and retains copy 5.

Typically attached to hazardous waste manifests are LDR notification/certification forms. LDR forms indicate to the TSDF that the waste either meets or exceeds certain technical treatment standards. Bridgewater State College is responsible for determining if certain wastes meet or exceed LDR treatment standards at the point of generation and signing a certification/notification, which is transmitted to the TSDF with the manifest.

A manifest requires a substantial amount of administrative and technical information. This information includes facility description (i.e. EPA ID number, address, phone number, contact person), proper DOT shipping name, hazard class and UN/NA number for the hazardous waste, type and quantity of container(s), additional descriptions and emergency information.

This section describes the required content of a manifest. Each item number below refers to a corresponding number on the referenced Massachusetts hazardous waste manifest. For each shipment of hazardous waste, these items must be completely and correctly filled in and provided to EH&S for review and verification.

Enter the appropriate Bridgewater State College EPA ID. The EPA ID numbers are as

Follows:

• Hazardous Waste Generator EPA ID #:
• Enter the Transporter's name and Transporter's EPA ID number.
• Enter the State of registration and license number of the waste-carrying portion of the transporter's vehicle.
• Enter the telephone number of the Transporter Company.
• Enter the TSDF (destination facility) name and address and the TSDF's EPA ID number.
• Enter the telephone number for the TSDF that can be reached to answer questions regarding the shipment.
• Enter the proper USDOT shipping name for the waste, the USDOT hazard class and the UN/NA ID number. (See USDOT Hazardous Materials Table 49 CFR 172.101 columns 2, 3 and 3A). Contact EH&S for assistance.
• Enter the number and type of container (refer to chart on back of manifest, e.g. DM = steel drum, TP = portable tank, etc.
• Enter the approximate weight or volume of the waste (refer to chart on back of manifest, G = gallons, P = pounds, etc.).
• Enter the proper EPA and/or DEP waste code(s) (see 310, CMR 30.120-30.136).
• Enter additional descriptions for wastes, which have, do not have a USDOT shipping name or "N.O.S." in their shipping name. This information includes constituent percentages, chemical names, physical states (S = solid, L = liquid, G = gas) and the EPA hazard code (I = ignitable, C = corrosive, R = reactive, E = EP Toxic, H = acute hazardous, and T = toxic. Enter the specific gravity if other than 1.0.
• Enter an emergency phone number, which can include the transporter's emergency number.
• Print, sign and date the manifest. Authorized EH&S personnel or College personnel who have received specific guidance from EH&S personnel may sign a manifest.

Ensure that the transporter prints, signs and dates the manifest. Check all 8 copies to ensure that the signatures are legible on all copies.

Retain appropriate copies (e.g. Massachusetts manifest copies 6, 7, 8) and the LDR forms. Submit all copies to EH&S office immediately; EH&S may need this information in the event the waste hauler experiences a highway emergency.

Training

Persons who complete and sign manifest require specialized and documented training in hazardous waste management and DOT compliance. EH&S personnel possess this training and requisite skills.

Reporting

If the waste facility does not return a signed copy of a manifest to EH&S within 45 days indicating that the waste was accepted at the facility, Bridgewater State College is required to submit an exception report to the DEP. Exception reports are completed by EH&S.

Record Keeping

Copies of manifests, exception reports, and LDR notification/certification forms are required to be maintained for not less than 3 years. As a means of effectively managing this recordkeeping requirement, coordinate the completion manifest/LDR forms through EH&S.