What are the regulatory requirements for making changes on hazardous waste manifests?
Your question doesn’t specify whether you are the generator who is preparing the hazardous waste manifest or the designated facility (TSDF) that is receiving the hazardous waste shipment. Assuming you’re the generator, it is the generator’s responsibility to ensure that the shipment is in compliance with applicable EPA and DOT requirements. The generator certifies with his/her signature in Item 15 of the manifest that the “contents of this consignment are fully and accurately described.”
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The federal regulations do not address how a generator may correct an incorrect entry once it is placed on the manifest and before the manifested shipment leaves the generator’s site. That said, there are no federal regulations which would prohibit the generator from neatly drawing a line through the incorrect information and entering it correctly. It is our understanding that this is a common practice along with initialing and dating the change. The generator must prepare an accurate and legible manifest; clearly crossing out the incorrect information and adding the correct information would appear to comply with that requirement. Item 18 of the manifest is for the use of the TSDF, not the generator.
Item 18 of the manifest is the “discrepancy” block that must be completed by the TSDF if the receiving facility finds there to be a “significant discrepancy” between the quantity or type of hazardous waste designated on the manifest and the quantity or type of hazardous waste actually received (40 CFR 264.72(a)). A significant discrepancy in quantity is defined as (40 CFR 264.72(b) to (c)):
• For bulk waste, variations greater than 10 percent in weight
• For batch waste, any variation in piece count, such as a discrepancy of one drum in a truckload.
Significant discrepancies in type of waste are obvious differences that can be discovered by inspection or waste analysis, such as waste solvent substituted for waste acid, or toxic constituents not reported on the manifest.
It would seem that a generator who corrects the manifest prior to shipment is avoiding the discovery of a significant discrepancy by the TSDF.