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By: Lisa Neuberger
Publication: Environmental Regulatory Alert
Date Posted: Oct 7, 2020
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:
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.
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