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:

If a generator is shipping multiple containers of a single waste stream, the waste does not have to be packaged in the same type of container to be on one line of the manifest. For example, if a generator is shipping spent solvent in both plastic drums (container type is abbreviated DF) and metal drums (abbreviated DM), the container abbreviation for both types of drums (i.e., DF/DM in this example) could be entered in Block 10 under “Type” and the number of each noted in Block 14 of the manifest. [DOT Interpretations 10-0256 and 11-0022]
Although hazardous waste transporters sometimes allow estimated weights to be used in Block 11, DOT recently provided guidance stating that (with few exceptions) “the exact quantity of hazardous materials covered by the description” should be entered on manifests. [DOT Interpretation 16-0163]

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This document addresses issues of a general nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with the environmental 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.