New Village Industrial Park — Hazardous Materials Safety Interpretation

Page 1of Transportation S.Department 400 Seventh Street. S.W Washington, D.C. 20590 Research and Simintrations JUN 2 2000 Ms. Daniel G. Fox Ref. No. 00-0114 Director of Training New Village Industrial Park 60 Commerce Drive Buffalo, New York 14218-1040 Dear Ms. Fox: This is in response to your letter dated April 11, 2000, requesting clarification on the hazardous waste manifest requirements under § 172.205(c) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether it is permissible for the shipper/generator to prepare, sign and date a manifest in accordance with 40 CFR Part 262 at the time it is offered for transportation, even though the initial carrier may not sign and date the manifest to accept the waste until three or four days later. Section 172.205(c) requires that the shipper/generator sign and date the manifest at the time the shipment is offered for transportation and the initial carrier at the time the shipment is accepted. The HMR do not prohibit the use of different shipper/generator and initial carrier dates on the manifest form. The Uniform Hazardous Waste Manifest (EPA Form 8700-22 and 8700-22A) is required by the U.S. Environmental Protection Agency (EPA). Therefore, you should contact your EPA regional office or state environmental office or EPA's RCRA Hotline at 800-424-9346 regarding different shipper/generator and initial carrier dates on the manifest. I hope this answers your inquiry. Sincerely, man Bullo Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 172.205 000114#

Page 2I ENDURING TAL HAZMAT GROUP, INC. uffalo, New York 14218-104 O Commerce Drive DO - OIl HAZARDOUS MATERIALS SERVICES.... TRANSPORTATION.... TRAINING...CONSULTING Permitted In 48 States and Canada Phouc: (716) 827-7200 www.hazmuatinc.com lax: (716) 827-7217 April 11, 2000 Mr. Edward Mazzullo Director - Office of Hazardous Materials Standards USDOT/RSPA DHIM - 10 400 7* Ave. SW Washington, DC 20590-001 Subject: Hazardous waste manifest Dear Mr. Muzzullo The DOT regulations at 49 CFR 172.205(c) state that the original copy of the manifest must be dated by, and bear the handwritten signature of, the person (1) The shipper (gencrator) of the waste at the time it is offered for transportation, anc representing: (2) The initial carrier accepting the waste for transportation. Question: Is the shipper (generator) at the time it is offered for transportation, allowed initial carrier may not accept the waste until three or four days later? In: the above to prepare, sign and date the manifest in accordance with 40 CFR Part 262, although the scenario, the date the generator signed the manifest and the date the initial carrier signed the manifest would differ. Are two different dates acceptable? Your clarification on this issue of different dates on the manifest would be greatly appreciated. Sincerely, Daniel G. Fox Director of Training 20 d#