Generators, transporters get more time to social distance

By: Lisa Neuberger

Publication: Environmental Regulatory Alert

Date Posted: 10/07/2020

Generators, transporters can use substitute signatures until Nov. 30

EPA has extended its temporary policy on signing paper hazardous waste manifests during the COVID-19 pandemic. The policy, first issued on May 18, 2020, outlined the agency’s temporary policy regarding how handlers of hazardous waste can address generator signatures on paper manifests during the COVID-19 pandemic. Known as the Manifest Signature Policy, the memo reinforced EPA’s Temporary Enforcement and Compliance Assurance Program which provided partial leniency to companies making good faith efforts to meet their regulatory requirements during the health emergency. While the good-faith enforcement policy expires on August 31, 2020, EPA is extending the Manifest Signature Policy to November 30, 2020.

Hazardous waste handlers told EPA that they anticipate the need for continued social distancing for obtaining “wet” signatures on paper hazardous waste manifests. They believe measures are needed to protect truck drivers and facility personnel in areas with high rates of COVID-19.

The temporary Manifest Signature Policy applies only to generator signatures required on the Uniform Hazardous Waste Manifest, EPA form 8700-22/22A. EPA urges all parties to use the electronic hazardous waste manifest (e-Manifest). If this is not a viable option, then the following steps should be taken:

  1. The transporter should write the name of the generator in Box 15 and, under “Signature,” should write “COVID-19 signature substitute” or abbreviated as “COVID-19 sig. sub.”
  2. The generator should provide a signature substitute in a cell phone text message, email, or hard copy letter mailed to the transporter and designated facility. The generator should use one document/transmittal to cover all manifest activities per transporter/designated facility throughout the duration of this temporary policy.
  3. The transporter of designated facility should write in Box 14 of the manifest “documentation for generator signature substitute available upon request.”

Generators and transporters taking these steps should maintain all documentation for three years from the last shipment needing a signature substitute.

Key to remember: EPA is extending its temporary policy allowing social distancing for signing the paper hazardous waste manifest during the COVID-19 pandemic.

About the author
Lisa Neuberger - EH&S Editor

Lisa joined J. J. Keller & Associates, Inc. in 2008. She serves as a resource for customers on environmental, health, and safety topics, and has a passion for the safe management of hazardous waste. She specializes in OSHA’s workplace injury and illness recordkeeping and reporting, flammable liquids, and sanitation standards and in EPA’s solid and hazardous waste regulations.

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