HAZARDOUS WASTE TRANSPORTATION
CUSTOMIZED ENVIRONMENTAL
TRAINING
WELCOME
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INSTRUCTOR
Insert Instructor Name Here
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OBJECTIVES
 Discuss the EPA ID Number Requirements for Transporters.
 Discuss Packaging, Labeling, Marking and Placarding
Requirements for Transporters.
 Discuss Compliance With the Hazardous Waste Manifest.
 Discuss the Transporter’s Responsibilities if a Hazardous
Waste Discharge Occurs.
 Discuss the Manifest Requirements for Different Modes of
Transportation.
 Discuss Transfer Facilities Responsibilities.
 Discuss Transporter Training Requirements.
 Discuss Reports and Recordkeeping.
 Recommend Inspection Items.
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GOALS
 Understand the EPA ID Number Requirements for Transporters.
 Be Familiar With the Packaging, Labeling, Marking and
Placarding Requirements for Transporters.
 Understand Compliance With the Hazardous Waste Manifest.
 Understand the Transporter’s Responsibilities if a Hazardous
Waste Discharge Occurs.
 Understand the Manifest Requirements for Different Modes of
Transportation.
 Understand Transfer Facilities Responsibilities.
 Understand Transporter Training Requirements.
 Understand Reports and Recordkeeping Requirements.
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BACKGROUND
 In 1998, 61,234 industries reported a total of 7.3 billion
pounds of hazardous chemicals released to the air, land
and water in the United States.
 The Department of Transportation annually issues over
500 warning letters, 100 tickets, 1,400 penalties and
collects over $7 million in total penalties for noncompliance of hazardous waste transportation
requirements.
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LEARNERS
 Supervisors
 Facility Engineers
 Maintenance Personnel
 Department Managers
 Building Occupants
 Process Specialists
 Environmental and Safety Committees
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OVERVIEW
The goal of this course is to provide supervisors
with the tools needed to safely transport hazardous
waste and remain in compliance. It recommends
practical, actions that can be carried out by facility
management, maintenance personnel and building
occupants. The course will help you integrate good
hazardous waste transportation management
activities into your existing organization and identify
which of your staff have the necessary skills to carry
out those activities.
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WHAT THIS COURSE DOES NOT DO
The course is not intended to provide information
detailed information on packaging, labeling, and
placarding of each hazardous waste. Nor is it
specific training for hazardous waste spills and
cleanup. These specialties required training beyond
the intended scope of this course. Where this
expertise is needed, outside assistance should be
solicited.
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RESOURCE CONSERVATION AND
RECOVERY ACT (RCRA)
RCRA addresses the management of
hazardous waste and the transportation of
hazardous waste
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FEDERAL REGULATIONS
Pertinent Regulations:
 40 CFR 263 – Standards Applicable to Transporters
of Hazardous Waste
 40 CFR 262 – Standards Applicable to Generators of
Hazardous Waste
 49 CFR 100-185 – Department of Transportation
Hazardous Materials Regulations
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OVERVIEW
 EPA has promulgated regulations governing the safe
transport of hazardous wastes from generator to
designated facility
 Section 263 applies to carriers transporting hazardous
waste within the United States when that waste is subject
to the manifesting requirements of Section 262
 Transportation means "the movement of hazardous
waste by air, rail, highway, or water”
 EPA promulgated the transporter requirements to be
consistent with appropriate DOT regulations
 In general, transporters of hazardous waste must
comply with the requirements of Part 263, as well as the
specific DOT requirements
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OVERVIEW
 DOT has incorporated RCRA hazardous wastes as
one of the types of hazardous materials that must be
transported according to DOT specifications
The Joint Uniform Hazardous Waste Manifest serves
as both the EPA tracking form and the shipping paper
required under DOT
This system allows the in-transit management of
hazardous waste to be regulated safely and efficiently
while allowing both EPA and DOT to retain enforcement
of their respective regulations
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OVERVIEW
 EPA regulates the off-site transportation of hazardous
wastes
 Part 263 does not apply to the on-site movement of
wastes within a facility's boundary
 The term on-site includes the transport of hazardous
waste between contiguous properties, even when
separated by a public road "provided that the entrance
and exit between the properties in at a crossroads
intersection, and access is by crossing, as opposed to
going along, the right-of-way"
Generally Part 263 does not apply to transportation of
shipments that do not require a manifest
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DEFINITIONS
 Transport vehicle means a motor
vehicle or rail car used for the
transportation of cargo by any mode
 Each cargo-carrying body (trailer,
railroad freight car, etc.) is a separate
transport vehicle
 Transportation means the
movement of hazardous waste by air,
rail, highway, or water
 Transporter means a person
engaged in the offsite transportation of
hazardous waste by air, rail, highway,
or water
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EPA IDENTIFICATION NUMBER
 A transporter is required to obtain an EPA ID number
before transporting hazardous waste
 Transporters obtain EPA ID numbers by completing
and submitting EPA’s form the Notification of Regulated
Waste Activity
 EPA issues transporter ID numbers for primary offices
or places of business, not individual transporting
terminals
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PACKAGING
 According to DOT’s 49 CFR 171.2(a), anyone who
offers or accepts a hazardous material shipment must
comply with the Hazardous Materials Regulations
(HMR)
 No person, individual or company may offer or accept
a hazardous material for transportation in commerce
unless the shipment complies with the HMR
 The shipper and the carrier share in the responsibility
to offer and/or accept only hazardous materials that
comply with the HMR
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PACKAGING
Preparation of hazardous materials for transportation is
the responsibility of the person who offers the material
for transportation
Unless otherwise provided, a hazardous material may
be offered for transportation in an approved packaging
or container only if the material is:
 properly classed,
 properly described,
 in a properly manufactured and tested packaging,
 in a packaging marked in accordance with the HMR,
 the package fully complies with 49 CFR Part 173,
178, and 179
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LABELING
 Before transporting or
offering hazardous waste for
transportation off-site, a
generator must label each
package in accordance with
the applicable Department of
Transportation regulations on
hazardous materials under 49
CFR part 172
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MARKING
 Before transporting or offering hazardous waste for
transportation off-site, a generator must mark each
package of hazardous waste
 Before transporting hazardous waste or offering
hazardous waste for transportation off-site, a generator
must mark each container of 110 gallons or less used in
such transportation with the following words:
HAZARDOUS WASTE—Federal Law Prohibits Improper
Disposal. If found, contact the nearest police or public
safety authority or the U.S. Environmental Protection
Agency.
Generator’s Name and Address ___________.
Manifest Document Number ____________.
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PLACARDING
 Before transporting
hazardous waste or offering
hazardous waste for
transportation off-site, a
generator must placard or offer
the initial transporter the
appropriate placards according
to Department of Transportation
regulations for hazardous
materials under 49 CFR part
172, subpart F
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COMPLIANCE WITH THE
MANIFEST
 EPA created a tracking mechanism to ensure that
hazardous waste sent to a treatment, storage, and
disposal facility (TSDF) reaches its destination
 The manifest is the central element of this system.
The Uniform Hazardous Waste Manifest (EPA Form
8700-22) and its instructions are found in the appendix
to 40 CFR Part 262
 The manifest is the control and transport document
that accompanies the waste during transport from its
generation site to its final destination facility
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COMPLIANCE WITH THE
MANIFEST
 40 CFR Part 263, Subpart B, dictates transporter
responsibilities for the manifest system
 Before hazardous waste can be transported, the
transporter must sign and date the manifest
 The transporter must then deliver the hazardous waste
shipment to the next transporter, the designated facility, or
the alternate facility listed on the manifest
 If the waste cannot be delivered to the designated
receiver, the generator must be contacted for further
instructions, and the manifest must be revised accordingly
 The manifesting responsibilities vary depending on the
mode of transportation
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HAZARDOUS WASTE
DISCHARGES
 If a transporter discharges or spills hazardous waste,
he or she is required to take immediate action to protect
human health and the environment
 "Immediate action" is not specifically defined,
however, it may include containing the spill, notifying
local authorities, and notifying the National Response
Center as required by DOT or Superfund regulations
 DOT may require a written report
 Federal, state, or local authorities may require a
transporter to take actions in response to a discharge or
spill if the discharge is determined to present a longterm hazard to human health or the environment
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DISCHARGE CLEANUP
A transporter must clean up any
hazardous waste discharge that
occurs during transportation or
take such action as may be
required or approved by Federal,
State, or local officials so that the
hazardous waste discharge no
longer presents a hazard to human
health or the environment
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MODES OF TRANSPORTATION
 Transportation of hazardous
waste from the generator to the
designated facility can be
accomplished by several means of
transportation
 The regulations establish
guidelines for the proper handling
and recordkeeping of hazardous
waste transported by highway,
water, rail, or air
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HIGHWAY SHIPMENTS
Highway transporters must complete the following
manifest and recordkeeping requirements:
 Sign and date the manifest
 Leave a signed and dated copy of the manifest with
the generator
 Ensure that the manifest accompanies the waste
 Obtain the dated signature of the next transporter or
the owner/operator of the designated facility, and
 Keep a copy of the manifest for at least three years
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WATER (BULK) SHIPMENTS
 Water transporters must comply with
the directions on the manifest, obtain an
EPA ID number, and be listed on the
manifest
 When shipping hazardous waste by
water, however, the manifest is not
required to physically accompany the
shipment
 Instead, the person delivering the
waste to the initial water transporter
obtains the date of delivery and signature
of the water transporter on the manifest
and forwards it to the designated facility
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WATER (BULK) SHIPMENTS
In addition, if the waste is delivered directly to the TSDF,
the water transporter must:
 Ensure that a shipping paper (e.g., waybill),
containing the same information as the manifest,
accompanies the waste
 Obtain the dated signature of the owner or operator
of the designated facility on the shipping paper or the
manifest
 Sign and date the manifest
 Retain a copy of the shipping paper or manifest for
three years
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RAIL SHIPMENTS
As with the other methods of transport, rail
transporters must have an EPA ID number and ensure
the designated facility is listed on the manifest
 Similar to water shipments, rail transporters must
comply with the directions on the manifest and must be
listed as a transporter on the manifest, but the actual
manifest form does not have to accompany the waste
shipments at all times
Instead, a standard waybill or other shipping
document containing all the manifest information except
EPA ID number, generator certification, and signatures
may accompany the waste
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RAIL SHIPMENTS
Initial rail transporter's duties include:
 Signing and dating the manifest
 Returning a signed copy of the manifest to the nonrail transporter
 Retaining a copy of the manifest and rail shipping
paper for three years
 Forwarding at least three copies to the next non-rail
transporter or designated facility (if the shipment is
delivered by rail), or the last rail transporter designated
to handle the waste in the United States
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RAIL TO TSDF
 For rail delivery to the designated
facility, the rail transporter must obtain
the dated signature of the owner or
operator of the designated facility on
the manifest or shipping paper, and
retain one copy of the manifest or
shipping paper for three years
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RAIL TO NON-RAIL
 For delivery by rail to a non-rail transporter, the rail
transporter must obtain the dated signature of the nonrail transporter on the manifest and must retain a copy
for at least three years
 Since the manifest is not required to accompany the
rail shipment, the non-rail transporters might obtain a
copy of the manifest directly from the generator
 If the hazardous waste is leaving the United States,
the transporter must receive an Acknowledgment of
Consent from the generator, and ensure that it
accompanies the shipment at all times
 The Acknowledgment of Consent is consent from the
receiving country to accept the shipment
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PIPELINE SHIPMENTS
 Transportation of hazardous
waste by pipeline does not meet
the RCRA definition of
transportation
 Piping as a mode of transport is
not specifically addressed by
RCRA, nor is it prohibited
 However, hazardous waste
piped off-site may be subject to
other provisions of RCRA
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TRANSFER FACILITIES
 A transfer facility is an area used to temporarily store
wastes on route to a TSDF
 Transfer facilities may be carrier terminals, loading
docks, or other areas where waste is kept during the
normal course of transportation
 Transporters may store manifested shipments of
hazardous waste in containers at a transfer facility for
10 days or less without a storage permit under Section
263.12
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TRANSFER FACILITIES
 Transfer facilities are not required to operate under
RCRA storage permits provided the waste is manifested,
kept in DOT specification containers, and stored less than
10 days
 There is no specific time limit for a hazardous waste
shipment to reach the designated facility.
If a LQG does not receive a signed copy of the manifest
from the designated facility within 35 days of the date the
initial transporter accepted the waste, the generator must
contact the transporter
 If a copy of the manifest is not received within 45 days
of the date the waste was accepted by the initial
transporter, then the LQG must submit an Exception
Report to the EPA Regional Administrator
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EXPORTING HAZARDOUS WASTE
 There are additional requirements
for transporters who export
hazardous waste
 Before waste can be exported to a
foreign country, the generator (or
primary exporter) must obtain the
country's approval for the shipment
via an acknowledgment of Consent
that is processed by the State
Department
 The regulations governing exports
of hazardous waste are found in Part
262, Subpart E
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TRANSPORTER AS A
GENERATOR
 Anyone, including a transporter, who imports
hazardous waste from a foreign country must comply
with the generator requirements, including initiating a
manifest
 If the transporter mixes wastes with different DOT
shipping descriptions by placing them in a single
container, the transporter must initiate a new manifest
and comply with the generator regulations
 The transporter should be named in the generator
block and the old manifest(s) should still accompany the
waste
 Additionally, any other substantial shipping changes
would require that a new manifest be prepared
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PERMITS, LICENSES, AND
INSURANCE
 Transporters do not need RCRA permits if they
comply with 40 CFR Part 263
 If the transporter stores hazardous waste longer than
10 days or treats or disposes of wastes at their facility, a
RCRA permit would be required
 In addition, states often require special permits or
licenses for transporters
Although EPA does not require transporters to have
liability insurance, the Federal Motor Carrier Act,
implemented by DOT, does require it
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EPA/DOT INTERFACE
 As part of the RCRA cradle-to-grave waste management
system, the transporter regulations ensure proper delivery of
the hazardous waste to the designated TSDF
 The 40 CFR Part 263 transporter requirements adopted
portions of the DOT regulations for the safe transport of
DOT classified hazardous materials
The DOT references in the RCRA regulations include
requirements for labeling, marking, placarding, and
containers, and also outline the DOT requirements for
responding to spills or discharges
 EPA incorporated these requirements by reference, to
ensure consistency with the DOT regulations and to avoid
duplicative and burdensome requirements
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TRANSPORTER TRAINING
DOT’s Hazardous Materials
Regulations (HMR) include training
requirements in several sections for
Hazardous Waste Transporters:
 GENERAL: 49 CFR 173.1
 SPECIFIC: 49 CFR 172.704
 MODAL: Air 49 CFR 175.20;
Vessel 49 CFR 176.13; Highway 49
CFR 177.800 and 177.816
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TRANSPORTER TRAINING
TRAINING REQUIREMENTS
Each hazmat employer must:
 train and test,
 certify, and
 develop and retain records of
current training (inclusive of
preceding three years) for each
hazmat employee (during the
period of employment and 90 days
thereafter)
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TRANSPORTER TRAINING
Hazmat training must include:
 General
awareness/familiarization,
 Function-specific,
 Safety, and
 Driver training (for each hazmat
employee who will operate a motor
vehicle).
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TRANSPORTER TRAINING
Initial training
 A new employee, or an employee who changes job
functions, may perform hazmat job functions before
completing training, provided:
- the employee does so under the direct supervision of a
properly trained and knowledgeable hazmat employee
- the hazmat training is completed within 90 days of
employment or change in job function
Recurrent training
 Required at least once every three years
 Relevant training received from a previous employer or
source may be used to satisfy the requirements
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TRANSPORTER TRAINING
Training Records must include:
 Hazmat employee's name;
 Completion date of most recent training;
 Training Materials (Copy, description, or location);
 Name and address of hazmat trainer; and
 Certification that the hazmat employee has been
trained and tested
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RECORDKEEPING
 A generator must keep a copy of each manifest 3
years or until he receives a signed copy from the
designated facility which received the waste
 This signed copy must be retained as a record for at
least three years from the date the waste was accepted
by the initial transporter
 A generator must keep a copy of each Biennial
Report and Exception Report for a period of at least
three years from the due date of the report
 A generator must keep records of any test results,
waste analyses, or other determinations made in
accordance with 40 CFR 262.11 for at least three years
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BIENNIEL REPORT
 A generator who ships any hazardous waste off-site to a
TSDF within the U.S. must prepare and submit a single
copy of a Biennial Report to the Regional EPA
Administrator by March 1of each even numbered year
 The Biennial Report must include the following
information:
(1) The EPA identification number, name, and address of
the generator;
(2) The calendar year covered by the report;
(3) The EPA identification number, name, and address for
each off-site TSDF;
(4) The name and EPA identification number of each
transporter
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BIENNIEL REPORT
(5) A description, EPA hazardous waste number, DOT
hazard class, and quantity of each hazardous waste
shipped off-site for shipments to a TSDF
(6) A description of the efforts undertaken to reduce the
volume and toxicity of waste generated
(7) A description of the changes in volume and toxicity
of waste actually achieved during the year in
comparison to previous years
(8) The certification signed by the generator or
authorized representative
 Any generator who treats, stores, or disposes of
hazardous waste on-site must submit a biennial report
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EXCEPTION REPORTING
 A generator of greater than 1000 kilograms/month
who does not receive a copy of the manifest with the
handwritten signature of the owner or operator of the
TSDF within 35 days of the date the waste was
accepted by the initial transporter must contact the
transporter and/or the owner or operator of the TSDF
 A generator of greater than 1000 kilograms/month
must submit an Exception Report to the EPA Regional
Administrator if he has not received a copy of the
manifest with the handwritten signature of the owner or
operator of the designated facility within 45 days of the
date the waste was accepted by the initial transporter
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EXCEPTION REPORTING
The Exception Report must include:
 A legible copy of the manifest for which the generator
does not have confirmation of delivery;
 A cover letter signed by the generator or his authorized
representative explaining the efforts taken to locate the
hazardous waste
 A generator of greater than 100 kilograms but less than
1000 kilograms of hazardous waste/month who does not
receive a copy of the manifest within 60 days of the date
the waste was accepted by the initial transporter must
submit a legible copy of the manifest, with some indication
that the generator has not received confirmation of
delivery, to the EPA Regional Administrator
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RECOMMENDED INSPECTION
ITEMS
 Determine if the facility transports hazardous waste
off-site by using their own vehicles or a contractor
 Verify that the transporter has an EPA identification
number
 Verify that all waste accepted, transported, or offered
for transport is accompanied by a manifest
 Verify that prior to transport, the transporter signs and
dates the manifest and returns a copy to the generator
prior to leaving the facility
 Verify that the transporter retains a copy of the
manifest after delivery
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RECOMMENDED INSPECTION
ITEMS
 Verify that all wastes accepted by
the transporter are delivered to the
designated facility listed on the
manifest, or the alternate designated
facility if an emergency prevents
delivery, or the next designated
transporter or the place outside the
United States designated by the
generator
 Verify that manifests are kept on file
for three years
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RECOMMENDED INSPECTION
ITEMS
 Determine what pre-transport procedures for
hazardous waste are used
 Inspect a sample of containers awaiting transport to
verify that containers are properly constructed and
exhibit no leaks, corrosion, or bulges
 Examine end-seams for minor weeping that indicates
drum failure
 Verify that labeling and marking on each container is
compatible with the manifests
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RECOMMENDED INSPECTION
ITEMS
 Verify that the following information is displayed on a
random sample of containers of 110 gal. (416.40 L) or
less in accordance with 49 CFR 172.304:
“HAZARDOUS WASTE - Federal Law Prohibits
Improper Disposal. If found, contact the nearest police
or public safety authority or the U.S. Environmental
Protection Agency.”
- Generator's name and address
- Manifest Document Number ____ .
 Verify that proper DOT placarding is available for the
transporter
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RECOMMENDED INSPECTION
ITEMS
 Verify that transport operators
have instructions to notify local
authorities and take clean-up
action so that the discharge does
not present a hazard
 Verify that transporters give
notice to the National Response
Center and report in writing as
required by 49 CFR 171.15 and
49 CFR 171.16
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RECOMMENDED INSPECTION
ITEMS
 Determine if the facility has a transfer facility.
If so, verify the following:
- Transfer facility storage is for 10 days or less
- DOT packaging requirements are met
- Shipments are manifested and manifests accompany
shipments
- Storage is consistent with good management practices
 Verify that transporters do not store manifested
shipments of land disposal restricted wastes for more
than 10 days
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TIPS FOR USING CONTRACTORS
 Remember, You Control Your Facility or Area!
 Review Procedures With Them Before Starting the Job!
 Ensure They Are Properly Trained!
 Determine Their Environmental Compliance Record!
 Determine Who Is in Charge of Their People!
 Determine How They Will Affect Your Facility’s
Environmental Compliance!
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ELEMENTS OF A SUCCESSFUL HAZARDOUS
WASTE TRANSPORTATION PROGRAM
1. DETAILED WRITTEN HAZARDOUS WASTE
TRANSPORTATION INSPECTION GUIDELINES.
2. DETAILED WRITTEN HAZARDOUS WASTE
TRANSPORTATION BEST MANAGEMENT PRACTICES.
3. EXTENSIVE EMPLOYEE TRAINING PROGRAMS
4. PERIODIC REINFORCEMENT OF TRAINING
5. SUFFICIENT DISCIPLINE REGARDING IMPLEMENTATION
6. PERIODIC FOLLOW-UP
Hazardous Waste Transportation 57/ 58
© Copyright Training 4 Today 2001
Published by EnviroWin Software LLC
THE IMPORTANCE OF A
CLEAN ENVIRONMENT
“I would ask all of us to remember
that protecting our environment is
about protecting where we live and
how we live. Let us join together to
protect our health, our economy,
and our communities -- so all of us
and our children and our
grandchildren can enjoy a healthy
and a prosperous life.”
Hazardous Waste Transportation 58/ 58
© Copyright Training 4 Today 2001
Carol Browner
Former EPA
Administrator
Published by EnviroWin Software LLC