Q&A: Is the entire name of the receiving facility required on the uniform hazardous waste manifest?

Q&A: Is the entire name of the receiving facility required on the uniform hazardous waste manifest?

A question from my website (October 10, 2017):

Do i need to print the entire name of a waste receiving facility as permitted, or can I abbreviate it?

My reply that same day:

Thank you for contacting me. I will try to answer your question below:

  • The USEPA instructions for completing the Uniform Hazardous Waste Manifest include the following:

Item 8. Designated Facility Name, Site Address, and U.S. EPA ID Number
Enter the company name and site address of the facility designated to receive the waste listed on this manifest. Also enter the facility’s phone number and the U.S. EPA twelve digit identification number of the facility.

  • There is nothing that I can find in EPA regulations that prohibits the abbreviation of the designated facility. Nor is it specifically allowed.
  • USDOT regulations at 49 CFR 172.201(a)(3) prohibit the use of abbreviations in the shipping description unless specifically authorized by regulations. However, the designated facility is not part of the shipping description.
  • State regulations may be more strict than those of the USEPA and may contain a prohibition on the use of abbreviations, though I doubt it. You may wish to check with the state of both the generator and designated facility.

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  • In sum:  I don’t recommend abbreviating information on the Uniform Hazardous Waste Manifest but cannot find anything in the regulations – either USDOT or USEPA – that specifically prohibits it.

I hope this helps. Please don’t hesitate to contact me with any other questions.

At that seemed to do it because I didn’t hear anymore from him.

While I prefer to give clear answers based on precise language of the regulations, sometimes that isn’t possible.  As in this instance, the regulations don’t always address every possible circumstance.  In those situations I think it best to be conservative and play it safe.