Federal regulations require generators and transporters of hazardous waste and owners or operators of hazardous waste treatment, storage, and disposal facilities to complete the hazardous waste manifest form (EPA Form 8700-22) and, if necessary, the continuation sheet (EPA-870022A) for both inter-and intrastate transportation of hazardous waste.
I don’t know about you but I’m already asleep!
Which may indicate why some many companies get fined for incorrectly filling them out? For instance, each item marked on the manifest must be within the lines of the box it is intended to be placed in. If the person completing the form marks an item on one of the lines of the box, guess what? It’s a $25 per incident fine!
$25 Fine for Marking the Box Incorrectly.
In this example, every entry that has a red rectangle around it could result in $100 in fines for the 4 possible infractions. If you have 10 to 100 or more manifests a year, that's a signicant amount of money you are losing for a simple mistake.
But it doesn’t stop there. What if someone signs the hazardous waste manifest that is not certified to do so? That’s an $8,500 Fine.
The signature section of the manifest form must be signed by a certified person. It cannot be printed, as we have shown.
The person who signs the manifest must have a DOT Manifest Certification.
These fines are for just incorrectly filling out the form. You still have to ensure that you use the correct codes in each section. Knowing which codes to use can be very complex and confusing. Most small generators have a great deal of difficulty completing hazardous waste manifest forms due to these complex codes. Just a simple drum of oily water that is 80% water and 20% oil needs to have a profile completed of the waste streams. Depending on the amount of waste and the number of waste streams you have, this could result in a 2 page profile. That profile needs to be sent to the facility and assigned a profile number. That number then needs to put on the hazardous waste manifest form for each stream.
It’s this level of complexity and level of Pain in the Buttsky that generators experience that results in IDR completing the hazardous waste manifests for our clients and helping avoid further potentially devastating fines.
Do you know if your EPA # is active?
This sounds like a no-brainer, but your generator ID # may be declared inactive by the EPA and you may not even know it.
Did you complete the DTSC Bi-Annual questionnaire?
If not, the EPA could have suspended your EPA # and that’s a problem. Check the status of your EPA # here.
Hazardous waste generators face massive regulations on a daily basis. This seemingly simple form can end up costing you dearly in hazardous waste manifest fines. Don’t put your company in a costly position, instead get help! Your hazardous waste transportation company should be able to help you with completing your manifest.