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Air Indoor Resources - Hazardous Waste Management

Disposal Manifests and Shipment of Hazardous Waste

It is unfortunate that disposing of small quantities of hazardous waste is so costly, since most hazardous waste transporters charge a minimum fee for on-site pickup. Typically, this fee exceeds the cost of the disposal. Therefore, some facilities respond by storing hazardous waste until it becomes economical for transporter pickup, putting the facility out of compliance by exceeding regulatory accumulation time limits or amounts.

Florida schools are allowed to use the disposal services of DEP’s Household Hazardous Waste Collection facilities. Often this avenue of disposal is less costly than using a private contractor. For more information, please refer to the following web pages:

Hazardous waste is managed from the point of generation to ultimate disposal, known as "cradle to grave.” Schools should realize that their liability does not end when the wastes leave the school property. Each manifest has a Manifest Tracking/Document Number that is a unique tracking number already preprinted on the manifest that can be traced back to the original generator of the waste.

A disposal manifest must accompany each shipment of hazardous waste from the facility door to the ultimate disposal site. It is very important to have the manifest appropriately filled out before you sign it. There are multiple copies that are required to be distributed to various entities. The EPA uniform manifest document uses form 8700-22 or 8700-22A (international), which is signed by the generator, transporter and ultimate treatment, storage, and disposal (TSD) facility staff.

CESQGs choosing to send their hazardous waste to off-site treatment, storage, and disposal (TSD) facilities must document delivery through written receipts and other records, such as bills of lading or shipping papers, with three years’ record retention. These shipping documents require the names and addresses of the generator and TSD, type and amount of hazardous waste shipped, and date of shipment.

School administrators must make sure they receive a copy of the three-signature disposal manifest stating that wastes have arrived at their destination and have been appropriately stored, treated, chemical land filled, and/or destroyed. If the generator has not received the three-signature copy of the manifest within 60 days of the date of shipment, the generator is required to file an exception report to the DEP.

The manifest has multiple copies for: the generator, each transporter, and TSD or disposal facility. A copy must also be returned to the generator confirming proper disposal. Florida does not require submission of a manifest copy to the DEP. Keep in mind that the most important copy of the manifest is the three-signature copy that is forwarded back to the generator from the ultimate disposal facility.

Uniform Hazardous Waste Manifest and Instructions is the same for the EPA and Florida DEP.

Any hazardous waste generator, including CESQGs that discharge more than 33.3 pounds per month of non-acute mixtures of domestic sewage and other waste that passes through a publicly owned treatment works (POTW), requires notification to the waste treatment facility.

Land Disposal Restrictions (LDRs) were imposed by Congress in 1984 to ensure that toxic constituents in hazardous wastes be treated before land disposal through mandatory technology-based treatment standards. Although you don’t need to be familiar with the treatment techniques, generators managing LDR wastes must meet certain notification, certification, waste analysis, and recordkeeping requirements pursuant to 40 CFR Part 268.7.

At the time the waste leaves the facility, a notification accompanies the initial shipment for each waste subject to the LDRs including the waste codes, the hazardous constituents present, and waste analysis data. Subsequent notification is only required if the waste or the receiving facility changes. Furthermore, if the waste can be land disposed without further treatment, a certification that the waste meets the applicable treatment standards is required.

The LDR notification must accompany the shipment manifest and must include the following information:

  • EPA waste code/number(s);
  • Identification of waste as nonwastewater or wastewater;
  • Waste analysis data, if available;
  • If characteristic waste, all addition hazardous constituents present;
  • Statement indicating whether or not the waste undergoes alternative treatment technology; and
  • Constituents treated in contaminated soil and statement that it does or does not meet LDR standards.

Generators are required to have the same recordkeeping and documentation responsibilities as the ultimate disposer, usually the Treatment, Storage and Disposal (TSD) facility. The LDR notification and certification paperwork is required to be maintained on-site at the facility for three years.

Contact Information

Wendy Murphy
325 West Gaines Street
Suite, 1054
Tallahassee, FL 32399
Phone: (850) 245-9295