Masonry Magazine June 1986 Page. 34
EPA WASTE REQUIREMENTS
**Q** Where do I obtain the Uniform Hazardous Waste Manifest to use when I ship my hazardous waste off my plant site?
**A** A hazardous waste manifest is a multi-copy form that you must fill out completely and use to accompany your hazardous waste shipments. Some states print their own versions of the Manifest with the state's name and logo and require use of the state Manifest form. These forms are available from state hazardous waste management agencies. Many transporters and facilities may also be able to provide you with the correct Manifest.
To determine which state's Manifest form you need to complete, use this system: (1) If the state to which you are shipping your waste has its own Manifest, use that Manifest form. (2) If not, use the Manifest of the state in which your waste was generated. (3) If neither state requires a state-specific Manifest, you may use the "general" Uniform Hazardous Waste Manifest-EPA Form 8700-22-which you can purchase from some commercial printers, or obtain from some transporters or waste management facilities.
**Q** What information is required on the Manifest?
**A** Effective September 22, 1986, federal law requires 100 to 1000 kg/mo generators to fill out all of the unshaded items on the Uniform Hazardous Waste Manifest. (The completed Manifest will also fully satisfy Department of Transportation requirements for shipping hazardous materials.) Even now, some states require generators to complete the entire Manifest, or to provide information beyond the items 3, 9, 11, 12, 13, 14, and 16 required under federal law as of August 5, 1985. To be sure you complete all necessary parts of the Manifest, contact your state hazardous waste agency, your transporter, and your receiving facility.
**Q** Why are there multiple copies of the Manifest?
**A** The Manifest form is designed so that shipments of hazardous waste can be tracked from their point of generation to their final destination, the so-called "cradle-to-grave" system. The Manifest is produced in a multi-copy format so that each step in the shipment process can be documented. Thus, the generator of the hazardous waste completes the Manifest, and turns the shipment and remaining copies of the Manifest over to the transporter. The transporter or hauler signs the Manifest, returns one copy to the generator, and turns the shipment and Manifest over to the facility that the generator designated to receive the waste. The facility signs the Manifest, gives one copy back to the transporter, keeps a copy, and sends the remaining copy back to the generator so the generator knows that the hazardous waste has reached its intended destination. Some states require that a copy of the Manifest also be sent to the state hazardous waste agency each time a shipment changes hands. Generators are required to keep a copy of each Manifest signed by the designated facility, in their files for three years following the date of shipment.
**Q** What if the generator does not receive a final copy of the Manifest confirming the facility's receipt of the shipment?
**A** Under the new federal regulations, 100 to 1000 kg/mo generators are not, as are larger generators, required to file "exception reports." However, while these generators are not required to file an exception report, EPA strongly encourages generators to use good business practice and perform the necessary follow-up to make sure their waste shipments reach the destination facility. Should a shipment be truly lost, it is in the generator's interest to notify EPA or the state in order to minimize any future liability.
**Q** How often should generators ship hazardous waste off their premises?
**A** Larger generators must ship their waste off-site at least every 90 days to avoid having to obtain a hazardous waste facility permit. The final regulations allow 100 to 1000 kg/mo generators to accumulate hazardous waste on-site for 180 days (or up to 270 days if the waste is to be shipped more than 200 miles) without the need for a permit so that generators may accumulate more economical quantities for shipment. Some states, however, allow only a 90-day accumulation period, even for 100 to 1000 kg/mo generators. Check with your state hazardous waste agency for information on the requirements that apply to you.
**Q** Where can I send my waste, and who can haul it?
**A** Since hazardous waste from 100 to 1000 kg/mo generators must be managed according to RCRA hazardous waste rules, only transporters and facilities which have EPA identification numbers can handle your hazardous waste. Furthermore, they must be authorized to handle your particular kind of hazardous waste. For information on hazardous waste transporters and management facilities in your area, contact your state hazardous waste agency or EPA regional office.
**Q** May I recycle my hazardous waste?
**A** Yes. In fact, EPA strongly encourages recycling as one of the best methods for managing hazardous waste. Waste shipped off-site for recycling may still be subject to manifesting as well as other transportation and storage requirements. These requirements, however, are not intended to discourage recycling. Contact your state hazardous waste agency, EPA regional office, or trade association for information on your specific waste recycling alternatives.
**Q** Where can small quantity generators get further information and assistance?
**A** Generators should contact their state hazardous waste agencies for information on the requirements they must meet. For questions on the new federal requirements or hazardous was waste regulations in general, or to obtain the number for their state hazardous waste agencies, generators may wish to contact their EPA regional office; EPA's toll-free RCRA Hotline, 800-424-9346 (in Washington, DC, 382-3000); or EPA's toll-free Small Business Hotline, 800-368-5888 (in Virginia, 800-468-4561).
***
Views of the Presidency
George Washington: "The magnitude and difficulty of the trust overwhelms one"... Thomas Jefferson: "It is a painful and thankless office"... John Adams: "No man who ever held the office of President would congratulate a friend on obtaining it"... James K. Polk: "No President who performs his duty faithfully and conscientiously can have any leisure"... James Buchanan: "The Presidency is a crown of thorns."-Braddock's Presidential Quotations.