In recent years, the Department of Toxic Substances Control (DTSC) has subjected waste generators in California to stricter rules, particularly regarding hazardous waste manifests. Yet, every year the DTSC finds approximately 500,000 mistakes on the manifests it receives, making it difficult for them to verify the proper and safe disposal of hazardous waste.
Some generators who fill out waste manifest forms themselves receive a Manifest Correction Letter from the DTSC stating that they are being fined due to errors found on their manifest. Initially, some of these fines do not seem significant, since they are typically around $20 per mistake, however making enough of these errors can add up quite quickly. Here are 6 frequently reported waste manifest mistakes that could result in fines;
- Inactive, incorrect, or invalid waste generator ID number: All California waste generators are required to have a generator ID number. If over 100 kg per month of RCRA hazardous waste is produced per month, the generator must also have a federal EPA ID number. Those who generate less than 100 kg per month of either RCRA or non-RCRA waste must have a state ID number.
- Improperly filled boxes: Believe it or not, failing to stay within the lines while filling out your hazardous waste manifest can result in a fine. Sincemanifests are read by optical scanners, manifests with these types of errors may be too difficult for the machines to read, causing the manifest to be booted from the system.
- Incorrect dates, failure to sign or incorrect signatures: The waste generator or an authorized representative must sign the manifest. Typically, these authorized individuals are responsible for overseeing the operation of the worksite, such as a facility supervisor or plant manager. The fine for having an unauthorized individual sign your manifest could be $8,000 or higher!
- Incorrect container, units of measurement, or quantity information: The correct number and type of containers, total quantity, and units of measure must be specific and precise. The instructions for filling out your waste manifest are printed on the back of every manifest. These instructions list container type abbreviation codes and the appropriate units of measurement.
- Incomplete or inaccurate waste codes: A California waste code is required for both RCRA and non-RCRA waste. What may seem like a simple error can be viewed as an effort to bypass the EPA’s regulations.
Be sure to thoroughly review any hazardous waste manifest before it is signed by you or an authorized representative. Ensure that only personnel who have undergone Hazmat Employee Training and EPA/DTSC Hazardous Waste Personnel Training are permitted to prepare, review, and/or sign the hazardous waste manifest.
Keeping up with hazardous waste regulations can be a challenge, especially in California where compliance demands change more often than ever before. Our Environmental Health and Safety staff is prepared to assist companies across a broad range of industries. And, with over 25 years of combined experience in the environmental field, our EHS staff is prepared to help you perform, and ensure safety with effective compliance solutions.