Waste Manifests and Disposal Tracking
Handling and Packaging
Asbestos waste must be wetted, bagged or wrapped in leak-tight containers, and labeled with the required warning. Containers must be handled carefully to avoid breaking the material. Category I and II non-friable waste that remains intact may be handled differently than RACM, but once it is broken it is treated as RACM. Traps include assuming all waste can go to a landfill that is not permitted to accept asbestos.
The Manifest Chain
Waste shipments are tracked by a manifest system. The generator completes the manifest, the transporter carries it, and the disposal facility signs and returns a copy. The generator must retain copies and reconcile the return receipt. Questions often test who signs which copy and how long records must be kept. Missing or unsigned manifests are a common violation.
Disposal Site Requirements
Waste must go to a site permitted to accept asbestos. The disposal site named on the notification should match the manifest. A change in disposal site requires an amended notification. Traps include naming a transfer station as the disposal site when the waste is later moved to a landfill.
Worked Example
A generator ships 40 bags of RACM to a permitted landfill. The manifest names the transporter and the landfill, the landfill signs and returns the receipt, and the generator files the receipt with the project records. If the landfill rejects the load, the generator must arrange an alternate permitted site and amend the notification if the disposal site changes.
Rule of Thumb
Every load needs a manifest that matches the notification, and every manifest needs a returned receipt on file. If the disposal site changes, amend the notification before the next shipment.