Hazardous Waste Manifest Discrepancy
You are at a generator’s dock in Pittsburgh to pick up 8 drums of spent chlorinated solvent for disposal. The shipping paper/manifest lists 8 drums of UN1993 Waste flammable liquid, n.o.s., Class 3, PG II, and the generator’s EPA ID number. On the dock are 10 drums. Two extra drums are unlabeled and not on the manifest. The generator’s shipping clerk says, “Take them anyway; we’ll add them to the manifest later and e-mail you the updated copy.” One of the listed drums has a CORROSIVE label applied over a FLAMMABLE LIQUID label, and the top label is peeling. The drums are 55-gallon steel, and the truck is a box van with no placards. The generator is 40 miles from the disposal facility.
1. What should you do about the two extra drums?
Read the worked answer
Do not accept the two extra drums. Hazardous waste must be properly manifested before it is transported, and the manifest must identify the waste, quantity, generator, transporter, and designated facility. “Add them later” is not acceptable because the unmanifested drums would be moving without the required tracking document, and they are also unlabeled. The driver should sign only for the 8 drums listed on the manifest, after verifying them, and should leave the two extra drums on the dock. If the generator insists that all 10 be taken, the driver should refuse the entire load and notify the dispatcher. Taking unmanifested hazardous waste could expose the driver and carrier to serious liability and is exactly the kind of shortcut the regulations are designed to prevent.
2. What must be corrected about the labels and placards before departure?
Read the worked answer
The peeling CORROSIVE label over a FLAMMABLE LIQUID label is not acceptable. The labels must be legible and must match the actual hazard of the material. If the material is UN1993 Class 3, the flammable liquid label is the primary label; any subsidiary corrosive label must be justified by the material’s hazards. The old or incorrect label should be removed or replaced so the package communicates the correct hazard. The shipping paper description must match the labels. The box van also needs placarding: 8 drums of 55-gallon solvent will normally exceed 1,001 lb, so the Class 3 Table 2 material requires a FLAMMABLE placard on both sides and both ends. The driver should not leave with unplacarded drums or with labels that do not match the manifest.
3. What must be on the hazardous waste shipping paper or manifest before you sign?
Read the worked answer
Before signing, the manifest must accurately list the generator’s EPA ID number, the transporter, the designated facility, the waste codes, the quantity, the number and type of packages, and the DOT basic description including the word “Waste.” For this load the DOT entry should identify UN1993, Waste flammable liquid, n.o.s., Class 3, PG II, along with the package count and total quantity. The emergency response information and telephone number must be available to the driver. The packages must be marked and labeled consistently with the manifest. The driver should compare the drums on the dock to the manifest, count them, and confirm that no extra or unlisted drums are being loaded. Sign only for the accurate, verified load; if the paperwork or packages do not match, correct them or refuse the load.