November 8, 2017

DOT Interpretations Affect Manifest Preparation

The Pipeline and Hazardous Materials Safety Administration (PHMSA) within DOT is responsible for issuing and updating the hazardous materials regulations (HMR). Since essentially all RCRA hazardous wastes will meet DOT’s definition of a hazardous material, there is significant interface between these two programs. PHMSA issues guidance on implementation of the HMR, and those interpretations occasionally impact hazardous waste transportation. The following PHMSA interpretations may affect preparation of the hazardous waste manifest:


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This document addresses issues of a general nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with the RCRA regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.