EHS & Waste Management

What Must I Do If I find a Quantity Discrepancy on A Hazardous Waste Manifest?

By December 30, 2020 No Comments

The first thing to do if you find a Quantity Discrepancy on A Hazardous Waste Manifest is to determine if the quantity discrepancy is significant or otherwise.

Significant differences between the quantity or type of hazardous waste designated on the manifest or shipping paper, and the quantity and type of hazardous waste that was received by the treatment, storage or disposal facility.

What constitutes a significant Quantity Discrepancy on A Hazardous Waste Manifest ? Examples are:

  • For bulk waste a significant differences in quantity are variations greater than 10 percent in weight.
  • For batch waste a significant differences in quantity is any variation in piece count, such as a discrepancy of one drum in a truckload.
  • Significant differences in the types are obvious differences which can be discovered by inspection or waste analysis, these include issues such as waste solvent substituted for waste acid, or toxic constituents not reported on the manifest or shipping paper.

Upon discovering a significant difference in quantity or type, the owner or operator of the hazardous waste treatment, storage or disposal facility must attempt to reconcile the discrepancy with the waste generator or transporter. If the discrepancy is not resolved within 15 days after receiving the hazardous waste, the owner or operator of the hazardous waste treatment, storage or disposal facility must immediately submit to the Regional Administrator a letter describing the discrepancy and attempts to reconcile it, and a copy of the hazardous waste manifest or shipping paper at issue.

See www.epa.gov for more information.

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