Expanded Hazardous Waste Training Module:

Expanded Hazardous Waste Training Module:

Manifests & Transportation Requirements (EPA RCRA + Colorado 6 CCR 1007-3)

EPA #: COR000243287

Training Summary

To ensure employees understand their responsibilities in reviewing, signing, and managing manifests prepared by our transporter (Barton Solvents) and to ensure hazardous waste leaves the facility in compliance with all federal and Colorado requirements.

Training Map

Why it Matters?

Roles & Responsibilities

Uniform Hazardous Waste Manifest - What to look for

Container & Transportation Requirements

Land Disposal Restrictions (LDR's)

Recordkeeping Requirements

Colorado-Specific Rules

Employee Responsibilites

Why it Matters?

• Legal Chain of Custody: The manifest is the proof that hazardous waste was shipped correctly and reached a permitted facility. • Generator Liability: Even though Barton Solvents prepares the manifest, our facility remains responsible for accuracy until the waste is received at the TSDF. • Inspections: EPA or CDPHE may request to review manifests during audits. Errors can lead to fines.

Roles & Responsibilites

Click each option to see what responsibilities fall on which party

Transporter

Generator

Uniform Hazardous Waste Manifest – What to Look For

• Generator Information
• Our facility’s name, mailing address, EPA ID number.
• Emergency phone number listed (24/7 contact = Emergency Coordinator).
• Transporter Information
• Barton Solvents’ company name and EPA ID number.
• Designated TSDF

• Name, address, EPA ID number of the receiving treatment, storage, or disposal facility.
• Waste Description
• DOT Proper Shipping Name (e.g., Waste Flammable Liquids, n.o.s.).
• UN/NA number (e.g., UN1993).
• DOT hazard class (e.g., 3 = Flammable Liquid).
• Packing group (I, II, or III).
• Number and type of containers (e.g., 4 drums, 55 gallons each).
• Hazardous Waste Codes (e.g., D001, F003, F005).
• Quantity
• Gallons or weight of each container.
• Generator Certification Statement

• Confirms waste is properly packaged, labeled, and marked.
• Must be signed by the trained generator representative.

Container & Transportation Requirements

Even though Barton manages the shipment, we are responsible for container readiness before pickup.

• Condition of Containers
• Drums in good condition (no rust, dents, or leaks).
• Lids and bungs closed securely.
• Labeling
• “Hazardous Waste” label applied.
• Contents identified (solvent waste, still bottoms, etc.).
• Accumulation start date visible (CAA only).

• DOT hazard class labels affixed (Flammable Liquid, Toxic, etc.).
• Palletizing & Securing Loads
• Drums must be banded or shrink-wrapped on pallets, if requested
• Spill pallets used as required
• Emergency Contact Information
• Emergency Coordinator’s phone number must be on manifest.
• Colorado 24-hour spill line (1-877-518-5608) should be available in case of transportation release.

Land Disposal Restrictions (LDRs)

• Every shipment must include LDR notifications. • Prepared by Barton but must be reviewed and signed by the generator. • Identifies treatment standards before land disposal. • Must be kept with the manifest records for at least 3 years.

Recordkeeping

• Signed Generator Copy: Must keep a signed manifest copy before shipment leaves site.
• TSDF Copy: A final, signed copy returned by the TSDF within 30 days.
• If not received within 35 days → must contact transporter and TSDF.
• If not received within 45 days → file “Exception Report” with CDPHE.
• Retention: Keep manifests, LDRs, and exception reports for 3 years.
• Biennial Report: Manifest data is used to prepare the Biennial Hazardous Waste Report submitted every even year by March 1.

Colorado-Specific Rules

• Colorado adopts all federal RCRA manifest rules. • CDPHE requires coordination with local fire, police, hospitals, and LEPC as part of your contingency plan. • Emergency incidents during transport must be reported to the Colorado 24-hour spill line. • Annual generator fees are based partly on waste generation tracked via manifests.

Employee Responsibilities

1. Prepare waste containers correctly before Barton’s arrival. 2. Review manifest carefully — do not sign until all information is verified. 3. Sign generator certification on manifest. 4. Ensure a signed copy is left with the facility before truck departs. 5. File manifest copy with facility records. 6. Follow up if return copy from TSDF is not received.

Transporter Responsibilites (Barton Solvents)

These responsibilites are specific to Milarc Cabinets & our arrangements with our transporter

• Prepares Uniform Hazardous Waste Manifest with waste descriptions, codes, DOT shipping information. • Ensures transporter EPA ID and TSDF information are included. • Signs manifest upon pickup. • Provides the generator with a signed copy before leaving site. • Transports waste to the designated TSDF.

Generator Responsibilities

• Reviews manifest for accuracy before signing (waste codes, container counts, volumes, EPA ID numbers, emergency contact information). • Signs generator certification: certifies waste is properly packaged, labeled, and prepared for shipment. • Retains a signed copy of the manifest before shipment leaves. • Tracks return copy signed by the TSDF (due back within 30 days). If not received, must follow up. • Retains records (manifest + LDRs) for 3 years minimum.