The actual question was:
Does the “JJK” designation by law have to follow the manifest number on a hazardous waste drum label?
The questioner made some assumptions here that I must correct before I can properly answer the question.
- U.S. Environmental Protection Agency (EPA) requires certain generators of hazardous waste (large quantity generator and small quantity generator but not the very small quantity generator) to complete, sign, and provide to the transporter a uniform hazardous waste manifest (the Manifest) for off-site shipments of hazardous waste. The Manifest is also required by EPA for off-site transportation of PCB waste. States with an authorized hazardous waste program may require use of the Manifest for non-hazardous waste regulated more strictly within their state.
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- Each Manifest is identified by a unique Approved Manifest Tracking Number (MTN) which is printed in the upper right corner of the Manifest.
- A company must register with and be approved by the EPA before it can print copies of the Manifest for use by themselves or others.
- The approved registered printer is identified on each Manifest by a three letter code. This three letter code is included as a suffix to the MTN.
- The letters “JJK” as a suffix to the MTN identifies the printer of the Manifest as J.J. Keller & Associates, Inc.
So, “JJK” is part of the Approved Manifest Tracking Number for Manifests printed by J.J. Keller and must be pre-printed on the Manifest by the forms printer.
Pursuant to 40 CFR 262.32 (recently modified by the Generator Improvements Rule), before offering hazardous waste for transportation off site a generator must mark each container of 119 gallons or less (aka: a non-bulk packaging) with the following words and information:
- “HAZARDOUS WASTE”
- Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.
- Generator’s Name and Address
- Generator’s EPA Identification Number
- Manifest Tracking Number
- EPA Hazardous Waste Number(s) – A new requirement of the Generator Improvements Rule and one that may not yet have been adopted by your state.
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Conclusion:
It is the responsibility of the generator to mark a non-bulk container of hazardous waste with the words and information mandated by 40 CFR 262.32. This includes the manifest tracking number. The manifest tracking number includes three letters as a suffix to identify the registered printer of the manifest. These three letters may be “JJK” or some other combination depending on who printed the Manifest.