Full Document:
RCRA Online Number: 14687
Title: TRAINING AND MANIFEST SIGNATURE REQUIREMENTS FOR GENERATORS
Document Date: 2003-11-19
To: Sherman
From: Springer
Organization of Recipient: Tetra Tech FW, Inc.
Description: Training requirements depend on generator status. Conditionally exempt small quantity generators do not have training requirements. Generators who ship hazardous waste are subject to both RCRA and DOT regulations and need to comply with both EPA and DOT training requirements. The generator certification language on the manifest is essentially the same as the DOT shipper certification. Generators or representatives signing the certification on their behalf certify that materials being shipped are properly classified, described, packaged, marked and labeled, and in proper condition for transport. DOT regulations assume and EPA interprets its regulations to mean that the person signing the certification has personal knowledge of the facts regarding a waste and its proper preparation for transport. Appropriate knowledge at a minimum would require the successful completion of DOT training requirements. The shipper certification language does not extend to the waste minimization statement on manifest. The company represented by the signor and the individual signor may be liable for regulatory compliance.
Superseded: Citations Changed
Regulatory Citation(s): 262.34(d)(5), 261.5, 262.34(a)(4)
Official ORCR Policy: Yes
Associated Topic(s):
Generators,
Hazardous Waste,
Liability (Hazardous Waste),
Manifest |
