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Distribution of the Uniform Hazardous Waste Manifest in Michigan

Distribution of the Uniform Hazardous Waste Manifest in Michigan

In an earlier article I summarized the responsibilities of a hazardous waste generator for the completion and distribution of the Uniform Hazardous Waste Manifest (Manifest).  Read: Use and Distribution of the Uniform Hazardous Waste Manifest.  That article dealt only with the Federal regulations of the U.S. Environmental Protection Agency (EPA).  In this article – and those that follow – I will detail the requirements of individual states regarding the distribution of the Manifest.  Since the regulations of a state with an authorized hazardous waste program must be at least as strict as those of the EPA and can be more strict (state regulations can’t be less strict than Federal regulations), state regulations may require more than those of the EPA.

In this article:  Michigan!

State regulatory agency:

Michigan Department of Environmental Quality (MDEQ).

Manifest copy distribution in Michigan:

  • Page 1 (top copy): “Designated facility to destination State (if required)”.  MDEQ requires a designated facility located within Michigan to submit to it this copy of the Manifest.
  • Page 2: “Designated facility to generator State (if required)”.  MDEQ requires a designated facility located outside of Michigan (the generator is located within Michigan) to submit to it this copy of the Manifest.
  • Page 3: “Designated facility to generator”.
  • Page 4: “Designated Facility’s copy”.
  • Page 5: “Transporter’s copy”.
  • Page 6 (bottom copy): “Generator’s initial copy”

State requirements to modify the EPA-required manifest copy distribution outlined above:

  • As noted above, the designated facility must submit to MDEQ either page 1 of the Manifest (if the designated facility is located within Michigan) or page 2 of the Manifest (if the designated facility is located outside of Michigan).  MDEQ does not anticipate that all out-of-state designated facilities are aware of this requirement or will take the time to comply with it since they are outside of MDEQ’s jurisdiction.  See next point.
  • It is the responsibility of the generator to ensure a copy of the Manifest, signed by an out-of-state designated facility, is submitted to the MDEQ.  Therefore, the generator must submit a copy of page 3 of the Manifest, once received from the out-of-state designated facility, to the MDEQ.  Submittal must be made within 30 days of the end of the calendar quarter the shipment took place.
    • Address to:  Waste and Hazardous Materials Division / Michigan Department of Environmental Quality /  PO Box 30038 / Lansing, MI 48909-7538
  • The generator is not required to mail a copy of the Manifest to the MDEQ if the waste went to an in-state designated facility.

Additional state requirements for the management of the uniform hazardous waste manifest:

  • Use of the Manifest is required for shipments of hazardous waste generated by a large quantity generator (LQG) or small quantity generator (SQG).
  • Use of the Manifest is optional for shipments of Liquid Industrial By-Products (formerly Liquid Industrial Waste).
    • This shipment may be documented on a Manifest or other shipping document if it meets the statutory requirements of Part 121.
  • Use of the Manifest is optional for shipments of hazardous waste liquid by a conditionally exempt small quantity generator (CESQG).
    • This shipment may be documented on a Manifest or other shipping document if it meets the statutory requirements of Part 121.
  • MDEQ has state-specific hazardous waste codes in addition to those of the EPA.
  • MDEQ has state-specific codes for Liquid Industrial By-Products.
  • MDEQ has state-specific codes for PCB Waste.
  • MDEQ follows the Federal rule for the Exception Report.
  • MDEQ follows the Federal rule for the Waste Minimization Certification.

Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

http://www.danielstraining.com/

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