One very common question that is frequently asked by members is what Environmental Protection Agency (EPA) or Department of Transportation (DOT) training requirements apply to a person signing a hazardous waste manifest. Hazardous waste manifests are multi-part forms that accompany all shipments of hazardous waste and must be used by Small and Large Quantity Generators of hazardous waste.
In reviewing EPA’s training requirements for hazardous waste generators (found at 40 CFR 265.16 Large Quantity Generators and 40 CFR 262.34(d)(5) for Small Quantity Generators), there is no specific training identified for the person actually signing the hazardous waste manifest. However, EPA relies upon DOT’s requirements for preparing and signing uniform hazardous waste manifests.
DOT requires that the person signing the manifest have “first-hand knowledge” of the information listed on the manifest and the regulations that apply to the waste. The generator must certify that the materials are properly classified, described, packaged, marked, and labeled, and in proper condition for transporting. The generator certification is required both by EPA (40 CFR 262.23(a)) and DOT.
The training requirements for hazardous materials employees are defined in the DOT Hazardous Materials Regulations at 49 CFR Part 172, Subpart H. These regulations specify that training is needed which covers general awareness/familiarization, function-specific procedures, and safety. The training must occur within 90 days of employment for new employees, and be repeated every 3 years (49 CFR 172.704).