Waste Solvent Manifest at the Atlanta Generator
At a hazardous waste generator in Atlanta, you are picking up eight 55-gallon drums of spent solvent. The manifest describes the material as 'UN1993, Waste flammable liquid, 3, PG II' and lists a 24-hour emergency response number belonging to the generator's environmental manager. Each drum has a FLAMMABLE LIQUID label, but one label is half missing and the drum is also dented near the bung. The generator's shipping clerk tells you the drums are 'empty enough' and asks you to sign the manifest as transporter so the plant can close for the day. The drums are not marked with the word 'Waste.' The trailer is a closed van, and the total gross weight of the eight drums is 4,400 lb. You have a copy of the emergency response information in the cab.
1. Is the manifest description acceptable, and what package marking is missing?
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The description is not acceptable. For a hazardous waste, the word 'Waste' must precede the proper shipping name, and the basic description must still follow the order proper shipping name, hazard class, UN number, packing group. The correct entry is 'Waste flammable liquid, 3, UN1993, PG II,' not 'UN1993, Waste flammable liquid, 3, PG II.' The drums also must be marked with the word 'Waste' as required for the waste shipment; the setup says that marking is missing. The 24-hour emergency response number is acceptable only if it is actually monitored at all times during transport and the response information is available. Have the generator correct the manifest and package markings before you sign as transporter.
2. What should you do about the damaged label, the dented drum, and the request to sign?
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A transporter's signature on a hazardous waste manifest is an acceptance of the waste as described and packaged. The half-missing label must be replaced with a proper FLAMMABLE LIQUID label. The dented drum near the bung must be inspected for leakage or structural damage; if it is leaking or unsafe, it must be overpacked or rejected. 'Empty enough' is not a legal category. Either the drum meets the RCRA empty definition and is not being shipped as waste, or it is regulated waste and must be packaged and marked accordingly. Do not sign until the defects are corrected. With 4,400 lb gross of Class 3 Table 2 material, the vehicle also needs a FLAMMABLE placard.