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Hazmat · Shipping Papers, Markings, and Labels

You are hauling hazardous waste under a Uniform Hazardous Waste Manifest. What does the regulation require of you and of that document?

1.Date and sign a copy on accepting the waste, by hand or by conforming electronic signature, carry it as you would a shipping paper, and keep your copy three years from the initial carrier's acceptanceCorrect answer
2.Sign the manifest electronically rather than by hand, which the rule does allow, and then keep no copy at all once the designated facility has signed for the waste, since its record is the one that counts
3.Carry the manifest only as far as the first transfer point, after which the receiving carrier's own copy governs the rest of the shipment and the document stops being your concern
4.Treat it as a commercial document rather than a shipping paper, since the Environmental Protection Agency and not the Department of Transportation prescribes the form itself

Explanation

A carrier accepting hazardous waste dates and signs a copy of the manifest at the time of acceptance, carries it during transportation in the same manner the subchapter requires for shipping papers, and retains its copy for three years running from the date the initial carrier accepted the waste. Paragraphs (c) and (d) call for handwritten signatures, on the original from the generator offering the waste and the initial carrier accepting it, and on a copy from each later carrier and from the designated facility, but the section does not leave handwriting as the only route: electronic signatures in conformance with the EPA electronic manifest rule are acceptable in lieu of the handwritten signatures those two paragraphs require, provided one printed copy of the electronic manifest bearing the electronic signature is provided to the initial transporter, and a copy of the electronic manifest satisfies the three-year retention requirement. What the section does not make optional is the retention, and each retained copy has to bear every required signature and date up to and including the ones entered by the next person who received the waste. No person may offer, transport, transfer or deliver the waste at all unless the manifest has been prepared, signed, carried and given over as the rule requires. The three wrong options each drop one of those elements, keeping no copy once the receiving facility has signed (the electronic signature is permitted, the empty file is not), ending the carrying and retention duty at a transfer point, or demoting the manifest below shipping paper status because another agency designed the form.

Source: 49 CFR 172.205(e) and (j)

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