The Basics of Transporting Chemical Waste
November 25, 2019

Chemical waste is transported through hazardous waste transporters through rail, water, air, or highway from one site to another. These transporters have an essential role in the management of hazardous waste systems as they take it from the point of generation to its final destination.

This system of taking it from the generator of the waste includes taking it to an off-site facility to recycle, treat, and store it, making it ready for disposal. It can also include transporting treated hazardous materials, depending on their classification, to an additional site for further treatment and disposal.

What Are Generators of Hazardous Waste Responsible for Regarding Transporting Chemical Waste

As a generator of hazardous chemical waste, you are required to know and understand the proper protocol regarding the EPAs hazardous waste manifest. This procedure is important for reasons ranging from general safety issues to protecting yourself from unnecessary fines.

The manifest is a crucial part of having your chemical waste transported for disposal. It is federally required by the Department of Transportation (DOT) and the Environmental Protection Agency (EPA). This manifest is necessary for every shipment of hazardous materials. Failing to have this paperwork with every shipment can result in repercussions from the federal bodies, along with hefty fines.

Chemical Waste Audit for Transportation Methods

The EPA or a state government agency can audit your facility regarding the method of transportation you use to dispose of your chemical waste. This possible audit is why you must be using a licensed and reliable service to take care of your hazardous waste needs.

If you are audited, you will be required to have all the correct papers and manifests. These are your documents and proof of shipping your generated chemical waste correctly. These documents are also your proof of shipping the materials within the required timeframe.

If you are a large generator of chemical or hazardous waste, you need to ship it out every ninety days without exception. Your paperwork will verify you are complying with these rules. If you go into an audit without the necessary papers, there are a couple of things that can happen.

After a lot of time and hassle, the first complication will be that you have to track down copies of your manifests. The other thing that can happen when you do not have the papers at the audit is that you can’t secure the documents and therefore have no way to prove you’ve complied with the laws. If the second is true, and you cannot locate the papers, you will be facing severe and costly fines.

This paperwork is critical to your company. Make sure you discuss these documents with your hazardous waste disposal service to make sure you have the correct paperwork. When you receive these papers, you need to file them where they will be easily accessed in case of an audit. Even should you never be audited, as these are performed on a random schedule, it is always better to be safe when it comes to federal compliance.

Ensure Hazardous and Chemical Waste Manifest are Correct for Transporting

It is not going to matter that you have the manifest as proof if those papers are not correctly filled out. It is critical for the transport service you are using, as well as the facility where your waste is going to have the correct paperwork.

If the transporter of your chemical and hazardous waste does not know what they are carrying, it could lead to dangerous situations. Some materials should not be physically close to other materials, and if they end up together during transport, there is a very serious risk for a catastrophe.

If the transport service should be involved in an accident and unknowingly has dangerous materials next to one another, it could result in dangerous and improper handling by first responders. This danger is the same for the receiving facility as it could cause serious injury or death if chemical and hazardous wastes are not properly handled.

Your manifest has to include all relevant emergency information that would save lives during an emergency situation.

Technology is expected to change how you keep manifests of your chemical and hazardous waste materials. It is expected to change to e-manifest that will make it much easier, more streamlined to create, fill-out, and file these important documents.

The e-manifest will benefit everyone involved in handling these dangerous materials. The generator, the transporter, the receiving facility, and the EPA will all find e-manifests easier to keep track and prove proper handling of chemicals and hazardous materials.

To ensure you are in compliance with your record-keeping and properly filling-out and filing your manifests, check with your local hazardous waste disposal service.

As the generator of chemical and hazardous waste, it is crucial to your business to understand your part in having your waste transported. For this reason, you should also understand the importance of having the right transportation company working with you to dispose of your materials. The following are some of the rules and regulations your transport service has to complete to be in compliance with the RCRA laws.

Who Can Be a Regulated Hazardous Waste Transporter?

The RCRA (Resource Conservation and Recovery Act) classifies a hazardous waste transporter as one who handles the off-site transportation of hazardous wastes inside the United States. Transporting hazardous materials off-site includes taking the hazardous material from the site or facility where it was generated to another off-site property or facility for storage, treatment, or disposal.

If the materials are transported within the generating facility’s property or boundaries, then transporter regulations do not apply. Example of on-site transporting would include:

  • Treatment Storage & Disposal Facility (TSDF) or generators transporting their hazardous waste materials within their property or facility
  • Transporting or moving the material within a geographically contiguous property, meaning the property is adjacent or shares a common border but has to be reached by a public road

If the properties are noncontiguous, then transporter requirements apply and must be followed.

  • RCRA (Resource Conservation and Recovery Act-) The RCRA is a public law that has created a framework for properly managing hazardous and non-hazardous solid waste. The law is mandated by Congress and gives the EPA authority to develop and enforce waste management programs. The EPAs authority extends from the ‘cradle-to-grave’ regarding hazardous waste materials. This means it regulates it from the generation, transporting, treating, storing, and disposal of all hazardous wastes in the country. They have put into place guidelines and policies to ensure these materials are handled safely to protect both human life and the environment. Not following these policies is against the law. 

What are the Requirements for Chemical Waste Transporting

The United States Department of Transportation (DOT) and the EPA jointly developed hazardous waste regulations for transporting hazardous materials on highways, waterways, rail, or on public roads. As a transporter of hazardous waste, a carrier is subject to several RCRA regulations as defined by Title 40 of the Code of Federal Regulations, part 263:

  • Must have an EPA Identification Number 
  • as the EPA tracks hazardous waste transporters. Transporters cannot transport hazardous waste if they do not first obtain an ID number. These IDs are different from the EPA ID numbers assigned to site-specific transporter IDs, which are assigned to a transportation company as a whole. If a company has been assigned an ID, then each of their trucks must use their unique number. 
  • Must comply with EPAs Hazardous Waste System, which is designed to track hazardous waste. The tracking begins from the time it leaves the generator’s site or facility until it reaches the off-site waste disposal facility where it will be stored, treated, or disposed of. The manifesting system varies depending on  how the materials are being transported (air, rail, highway, etc.). Before your hazardous waste disposal service can accept your wastes, you must supply them with a properly prepared manifest. This manifest is required to be signed and dated to acknowledge the receipt, and they will then provide you with a copy before leaving.
  • Handle all Hazardous Waste Discharges or Spills. If, while transporting your hazardous waste, an accidental spill or discharge occurs, the transporter is required to take immediate and appropriate action. This action is necessary to protect human health and the environment. The action includes notifying the local authorities and diking the discharge and immediately removing the waste if it is required to protect human health or the environment. Some situations may require notifying the National Response Center, and the DOT may require a written report regarding the incident. 
  • Obey all Applicable DOT Hazardous Waste Regulations.
  • In order to avoid unnecessary regulations or discrepancies, transporter regulations have adopted portions of the DOTs regulations for the safe transport of classified hazardous materials. These requirements cover labeling, marking, and placarding containers. Transporters of hazardous waste materials should check with the DOT to ensure they are complying with all DOT regulations. 

Transferring Your Chemical Waste to a Transporter

Transporters accepting chemical waste or hazardous materials from a generator or another transporter can hold the waste temporarily during the course of moving it to another location. This transfer facility is defined as a transportation-related facility. It can include a parking area, loading dock, storage area, or another similar area where the shipment will be temporarily held.

The transporter of hazardous waste can hold the chemical waste without a storage permit in containers for up to ten days as long as the waste is manifested and kept in a DOT specified container. If the materials are held for longer than ten days, the transfer facility then becomes a storage facility which is subject to all applicable requirements.

Choosing the right hazardous waste disposal service will ensure you are in compliance with all chemical waste disposal, including the transportation of these wastes.


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