February 15, 2021

Frequent Questions on Waste and Coronavirus

EPA maintains a list of frequently asked questions related to COVID-19 and how the virus impacts its various environmental programs. Included is a set of questions and answers on waste and the coronavirus. There, the agency answers questions including the status and management of wastes containing the virus, whether extensions are available for accumulating hazardous waste for more than 90/180/270 days, the possibility of importing or exporting virus-impacted wastes, and how paper manifests should be signed.

One of the questions on the FAQs list discusses manifesting procedures during the pandemic. For part of 2020, an EPA policy was in place that provided alternatives to hand-signing hazardous waste manifests. These included authorizing the transporter or designated facility to sign in lieu of the generator or signing digitally via the e-manifest system. This policy lapsed in November 2020 and was not extended as EPA found less than two dozen instances of its use. Additionally, the agency’s conversations with TSD facilities confirmed that these companies are relying on other mitigation strategies to reduce risks from COVID-19 during interactions with generators and transporters.

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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.