“Please be aware that DTSC will be stepping up its efforts to review manifests and require manifest error corrections.” – DTSC Letter to Generators, August 2014
Hazardous waste generators in California recently received an alert from the Department of Toxic Substances Control (DTSC) by mail. The DTSC’s letter addresses a growing problem with Hazardous Waste Manifests: DTSC finds mistakes on many of the roughly 500,000 Manifests it receives and compiles in the Hazardous Waste Tracking System (HWTS) each year. These mistakes make it difficult to verify proper transport and disposal of waste. To help remedy this, DTSC will now charge a correction fee for mistakes they identify.
Manifest issues are more pronounced in California than in other states, in part because California generators and TSDFs must provide copies of the Manifest to State authorities. To help generators prepare accurate and complete Manifests for RCRA and non-RCRA wastes, Lion Technology will present a newly designed exhibit on Manifests at the Hazardous Waste in California Workshops in 2015.
Discrepancies vs. Mistakes
Manifest mistakes should not be confused with the discrepancies that generators may have encountered in the past. To avoid DTSC fees for mistakes on Manifests, personnel must know how mistakes differ from discrepancies and how the DTSC treats the two differently.
Discrepancies occur when a hazardous waste shipment does not match the information provided on the Manifest. These often include a mismatch of the type or quantity of waste, rejected shipments, or residues in a container shipped as “empty.” Discrepancies can typically be resolved between the TSDF and the generator. If the TSDF alerts the generator of a discrepancy and the generator does not respond within fifteen days, the TSDF must notify the DTSC.
Mistakes are more common errors, like typos and omissions, which can now result in DTSC fees. To avoid a correction fee of $20 for each mistake, generators should review Manifests for the most common mistakes and submit a correction letter to the DTSC. DTSC will not charge a correction fee if the company submits a correction before DTSC identifies the error.
8 Common Manifest Mistakes:
- Incorrect, invalid, or inactive generator ID number
- Failure to delete entire pre-printed information for waste not shipped
- Incorrect or incomplete container, total quantity, and/or unit weight information
- Waste codes incorrect or incomplete
- Failure to sign and/or date the Manifest
- Incorrect or incomplete dates; past dates or future dates
- Failure to submit a legible copy
- Generator fails to submit an exception report to DTSC when a signed facility copy is not returned within 45 days
Expert Training on CA’s Title 22 Regulations
2014 CUPA Conference presenter Lion Technology will present the Hazardous Waste in California Workshop in cities state-wide in January 2015: Los Angeles on January 8-9, Santa Barbara and San Francisco on January 12-13, and Fresno on January 15-16.