A Checklist For Packing & Shipping Hazardous Waste
July 31, 2024
In the past, TSDFs (treatment, storage, and disposal facilities) would try to accommodate hazmat generators if and when they made errors in the packaging and/or shipment of a hazardous waste. But in the face of stricter EPA regulations and the attendant legal/financial risks, most TSDFs won’t accept a hazardous waste if anything is wrong at all.
This blog entry provides a checklist for hazmat generators to use before packaging hazardous waste for shipment to a TSDF. The items are listed briefly below—but scroll down to learn the hows & whys. The checklist items are:
- Identify and characterize the hazardous waste generated.
- Determine the EPA hazardous waste codes applicable to the waste.
- Manage your containers.
- Make sure your containers are labeled to EPA specifications.
- Make sure your containers are “marked” and labeled to DOT specifications.
- Prepare an e-Manifest.
- Arrange transportation to the TSDF.
1. Identify and characterize the hazardous waste generated.
The EPA requires you to create a Hazardous Waste Profile (formerly known as a “waste characterization profile”) for any instance of hazardous waste removal. It requires you to list the chemical properties of the particular type of waste you intend to dispose of or otherwise transport, and it must be presented to the treatment & disposal facility (TSDF) prior to its arrival. Otherwise, it’s illegal for the TSDF to accept your shipment at all.
Listing every constituent of your hazardous waste allows a TSDF to determine in advance of delivery whether they are legally qualified to accept such waste at all and (if so) how they will manage it (e.g., landfill, incineration, or further processing). It also addresses more pedestrian concerns such as whether the TSDF has the necessary capacity at the time.
Much of the information you need to complete your Hazardous Waste Profile is likely extant in the Waste Analysis Plan that you filed as part of your EPA permit application to become a hazardous waste management enterprise in the first place. The difference between the two, of course, is that your Hazardous Waste Profile is concerned with a specific waste you wish to dispose of while your Waste Analysis Plan speaks to the sorts of hazardous materials you dispose of or transport generally.
Bear in mind that any Hazardous Waste Profile you develop must be presented with your signature (or that of one of your listed managers) attesting to its veracity. Thus, accuracy is paramount for avoiding EPA fines, sanctions, or worse.
And here’s a pertinent aside: a similar profile is required of waste you’ve determined to be nonhazardous and want to transport to a TSDF. Hazardous or not, you must assay the specific waste, document your analysis, and present that analysis to the receiving facility before you can transport it and they can accept it from you.
2. Determine the EPA hazardous waste codes applicable to the waste.
The EPA system of codes for identifying, handling, and disposing of hazardous waste is a complicated affair, and so a comprehensive explanation is beyond the purview of this blog entry. (You can get expert advice here.) That said, there are four main lists of EPA hazardous waste codes. In order of relevance:
- P List—is for acutely-toxic hazardous wastes from discarded commercial chemical products. Alphanumeric examples include:
- P001 – Folic Acid (a B vitamin)
- P010 – Mercury fulminate (a highly explosive compound)
- P022 – Sodium azide (used in airbags and explosives)
- P042 – Phosphines (highly toxic nerve agents)
- P068 – Strychnine (a very poisonous alkaloid)
- P075 – Tetranitromethane (a powerful explosive)
- P098 – Zinc phosphide (a rodenticide)
- P102 – Cyanide solutions (extremely toxic)
- P114 – Diethyl arsine (a toxic nerve agent)
- P123 – Isocyanates (highly toxic respiratory irritants)
- F List—is for hazardous wastes from common industrial and manufacturing processes. Alphanumeric examples include:
- F001 – hazardous wastes from non-specific sources
- F002 – hazardous wastes from specific sources that contain spent halogenated solvents
- F003 – hazardous wastes from specific sources that don’t contain spent halogenated solvents
- K List—is for hazardous wastes generated by specific industries. Alphanumeric examples include:
- K002 – wastewater treatment sludge resulting from the production and processing of yellow and orange pigments
- K009 – distillation bottoms from the production of acetaldehyde from ethylene
- K013 – bottom stream from the acetonitrile column in the production of acrylonitrile
- U List—is for hazardous wastes from off-specification commercial chemical products. Alphanumeric examples include:
- U001 – Acetaldehyde (flammable and toxic)
- U002 – Acetone (flammable solvent)
- U003 – Acetonitrile (flammable and toxic)
- U012 – Benzene (carcinogen and toxic)
- U022 – Chloroform (suspected carcinogen and CNS depressant)
- U031 – Dieldrin (persistent organic pollutant and insecticide)
- U040 – Endrin (highly toxic insecticide)
- U050 – Formaldehyde (carcinogen and respiratory irritant)
- U078 – Methyl bromide (flammable and toxic fumigant)
- U112 – Trichloroethylene (suspected carcinogen and potent solvent)
3. Manage your containers.
Hazmat containers must be in good condition, compatible with the waste, and adequately sealed to prevent leaks during transportation. Per the EPA, they must be properly labeled. Per the DOT, they must be properly “marked” (see Items 4 and 5).
4. Make sure your containers are labeled to EPA specifications.
According to EPA rules, a container used for hazmat onsite storage must be marked with the words “Hazardous Waste.” It must also exhibit the starting date for its accumulation along with information about its contents (e.g., toxic, reactive, ignitable, or corrosive).
If you’re reusing a container, make sure to remove old labels. And whether new or used, make sure to place a label on a container the very first moment that a hazardous waste is placed inside it. Otherwise, you’re out of compliance—and your intention to have done so at your very first convenience will not mollify a cranky EPA inspector.
To avoid visual confusion, all your personnel should be using the same labeling method (e.g., handwritten vs. printed forms). And each should have a clear understanding of what the markings signify—regardless of whether he or she directly tends to your hazardous waste disposal efforts.
Also bear in mind that labeling requirements differ depending on the amount of hazardous waste you generate. In this regard, the EPA specifies two categories: Non-bulk packaging (see 172.301 here) and Bulk packaging (see 172.302 here).
Loosely speaking, non-bulk packaging dictates a maximum capacity of 119 gal. for a liquid waste (450 L); a maximum of 882 lbs. for a solid waste (400 kg); or a water capacity of 1000 lbs. for a gaseous waste (454 kg). Thereby, bulk packaging is anything that exceeds these quantities.
As in all things involving the EPA, expert advice is crucial.
5. Make sure your containers are “marked” and labeled to DOT specifications.
According to DOT rules, not only must the container be clearly labeled as hazmat, it must also prominently display this notice: HAZARDOUS WASTE—Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.
Additionally, the container must clearly show your company’s name, EPA identification number, and manifest tracking number; and there might be additional requirements for bulk packaging containers (see Item 4).
Labeling must be durable, clearly visible, and written in English. It must be displayed on a contrasting color background and not be obscured by other labels, attachments, or advertising.
For DOT purposes, the word “labeling” is an extremely specific thing and is applicable only to bulk packaging (see Item 5). “Labels” are always diamond-shape; and their size must adhere to international standards, measuring at least 4” x 4” (100 mm) on each side, square-on-point. Everything else (applicable to non-bulk packaging) is merely “marking.”
The DOT uses nine categorical HazMat labels: 
- Explosives
- Compressed gas
- Flammable & combustible liquid
- Flammable & reactive solids
- Oxidizers & organic peroxides
- Poisonous materials & infectious substances
- Radioactive materials
- Corrosives
6. Prepare an e-Manifest.
Since 1976, the Resource Conservation and Recovery Act (RCRA) has required that a manifest accompany the movement of a hazardous waste from its point of origin (aka: the generator) to the hazardous waste management facility that’s legally “permitted” by the EPA to provide for its hazardous waste disposal (aka: the destination facility).
This manifest, completed by the generator, indelibly attaches a defined hazardous waste to your enterprise as it migrates from your site toward the hazardous waste management facility that will ultimately process it—along with all the legal, financial, and social liabilities that are endemic to hazardous material removal.
As of June 2021, the EPA no longer accepts mailed paper-and-pencil manifests for processing. Hazardous waste manifests must be submitted via the EPA e-Manifest program for TSCA regulated PCB waste, state regulated waste, and non-RCRA wastes. You must be registered with the e-Manifest system in order to use it.
You can get expert advice about the e-Manifest here.
7. Arrange transportation to the TSDF.
The EPA requires all hazmat haulers to have an EPA ID number, which is assigned to a transportation company as a whole, rather than requiring each of its trucks to have its own unique ID.
It is solely your responsibility to ensure that the transporter you hire to deliver your hazardous waste to a TSDF is properly licensed, “permitted,” and equipped to handle hazardous materials.
Because hazardous waste transporters use public roads, highways, rails, and waterways, regulations for container specifications, labeling, marking, and placarding are primarily developed by the DOT, with EPA input.
Hazmat transporter personnel must receive training that includes but is not limited to:
- Security awareness training about the security risks associated with hazmat transportation, and specific methods designed to diminish them.
- Function-specific training relative to the particular knowledge and skills required for an individual to perform assigned hazmat-transport responsibilities properly and safely.
- Safety training for drivers, warehouse workers, and any other employees who handle any hazardous waste in advance, during, and/or subsequent to its transportation.
- Specialized driver training pertaining to vehicle inspection and operation; vehicle handling in diverse conditions; and special rules pertaining to tunnels, bridges, and railroads.
- Advanced security training for companies required to have a security plan relative to their hazardous waste management.
- HAZWOPER certification for employees who must drive onto hazardous waste sites, enter EPA-regulated TSDFs, or respond to hazardous waste emergencies.
Our best advice:
While this blog entry provides an excellent resource and starting point for hazmat generators, be cautioned that no checklist can be truly comprehensive. More than one agency propagates rules for packaging and transporting hazmat: the EPA, DOT, FMCSA, and even the TSA. And too many kinds of hazmat exist that need to be transported under too many kinds of different circumstances. In sum, especially if you only have occasional or circumstantial need for hazardous waste removal, it’s important to have access to expert advice.
The best is found here.
And thank you for reading our blog!