Ask the Expert, Hazardous and Solid Waste

Should My Hazardous Materials Be Shipped on a Hazardous Waste Manifest or on a Bill of Landing?

Q. We ship some hazardous materials generated as part of our lead acid battery recycling process for further reclamation by a recycler. Should the hazardous materials be shipped using a hazardous waste manifest or should they be shipped as a hazardous material on a bill of lading?

A. Unless there is an applicable exception, you are required to use a hazardous waste manifest for the transport of materials that you have determined are hazardous waste (40 CFR 262.20(a) and 49 CFR 171.78). For example, if lead acid batteries are managed in accordance with either the universal waste provisions of 40 CFR 273 or the requirements at 40 CFR 266.80 for lead acid batteries being reclaimed, a hazardous waste manifest (EPA Form 8700-22) is not required.

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