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The Most Common and Costly Mistakes Made When Completing a Uniform Hazardous Waste Manifest

September 4, 2019

The EPA has little patience for sloppy Uniform Hazardous Waste Manifests

While thinking “out of the box” metaphorically might be good for your entrepreneurial endeavors, it can get you literally into trouble with the EPA. For example, failing to stay within the lines while filling in those little boxes on a Uniform Hazardous Waste Manifest can cost you.

No, we’re not kidding

Bureaucrats are paid to enforce rules. Thus, rules tend to become ends unto themselves without regard to why they exist in the first place. Such is the nature of petty tyrannies. So if you enter a perfectly correct number, but it isn’t positioned just so, you can get a $25 fine per instance.

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How can that possibly occur?

Well, if you’re hand-entering the data, it might be unlikely. But if you’re using a general word-processing program, a non-dedicated spreadsheet, or (OMG!) a typewriter to get the job done, where the numbers land can be hit-or-miss.

Be off-target two or three times, it can total to $50 or $75; and say you run 10 manifests a year— you’re looking at $500 to $750 in petty fines. That’s a lot of beer money.

Okay, to be fair, let’s concede that numbers “outside the box” are a challenge to optical scanners, and so the offending manifest might get kicked out of the system and need to be tended by a “real human being,” who might possibly have better things to do.

That adds time and cost to the endeavor; and so the fines are there to keep you neat, tidy, and thereby computer friendly.

This is just one of the many reasons why it pays to invest in a software platform built specifically around EPA requirements for hazardous waste management, whether yours is a generator, transporter, or storage enterprise.

What else can possibly go wrong?

As in all things involving the EPA, too much. For example:

Expired EPA ID. One of the most frustrating gaffes is finding out that your EPA ID has expired, which can happen if you fail to complete the required EPA Biennial Waste Report.

Among other things, this form-filling exercise requires you to document what efforts you’ve undertaken in the previous two years to reduce the volume and toxicity of the hazardous wastes you generate, and whether there have been any improvements in that regard.

Don’t file it, and an expired EPA ID might be the least of your problems.

So here again, the benefits of dedicated waste management software specifically designed for hazardous waste management are obvious—as such provides a historical record by which you can track pertinent changes and keep other data current as demanded by the EPA.

Missing or inaccurate generator, transporter, or facility EPA IDs. Remember that EPA IDs are always 12 digits long. Be careful. It’s easy to transpose digits. And if you have more or less than 12 of them, you’ve got trouble. Also bear in mind that if you have more than one transporter, you must list a separate EPA ID for each.

Inaccurate container and quantity counts. The EPA is definitely humor-challenged when it comes to losing track of a hazardous waste. Inaccuracies will likely bring you beaucoup bureaucratic scrutiny—which is French for “trouble.”

Erroneous waste codes. It might just be a bookkeeping error to you, but to the EPA it’s the mislabeling (and thereby misidentifying) of a hazardous waste. Was it just an innocent error by one of your employees, or part of your ongoing evil conspiracy to circumvent EPA rules?
N.B. You’re not the one who’s going to get to decide.

Wrong units of measure. Use of decimals or fractions when listing total weights in Item 11 is a no-no, which is why the offending entry (in the graphic above) would merit two fines @ $25 each—not just one. Also, citing pounds when and where the EPA wants you to wax prosaically about gallons (or vice-versa) will also earn you a penalty. They’re funny that way.

Unauthorized signatures. The person who signs your manifest must be qualified to do so. Typically, this will be the person responsible for the overall operation of your site (i.e., plant manager or superintendent, or a person of equal responsibility). The fine for instead having your good for nothing brother-in-law do it runs well north of $8,000. Find him a different job.

Mismatched dates, transporter names, and/or EPA IDs. Dates specific to a shipment of hazardous waste must be consistent across all paperwork. Ditto for transporter and generator names: they should be exactly the same as assigned to the EPA ID number and transporter registration, respectively. Discrepancies will cause you a world of woe.

Getting ahead of errors: neatness counts

It’s relatively easy to correct mistakes on a Uniform Hazardous Waste Manifest prior to its being signed by your authorized representative—so long as it’s done neatly. (Got white-out?) And you don’t need to initial corrections, since nothing’s been signed anyway. But too many corrections might make it prudent to start over. You gotta show respect.

So what’s the upshot?

It’s essential to have systems in place to accurately track the ebb and flow of your hazardous waste management. You can’t do this anymore with just index cards and Postem Notes®.

Minimally, you need software. Ideally, a platform that’s purpose built to manage and document the peculiarities and legalities of hazardous waste management; and that will consistently and accurately populate various EPA forms with numbers, codes, and other data across the multitude of legal documentation required by state and federal authorities.

Learn more about the best hazardous waste management software.

Disposal of hazardous waste doesn’t have to be painful.