The use, storage, and disposal of equipment containing PCBs (Polychlorinated biphenyls) is subject to USEPA regulations in Part 761 of Title 40 of the Code of Federal Regulations (40 CFR 761); regulations promulgated under the Toxic Substance Control Act (TSCA).  Despite a persistent belief to the contrary:  PCBs are not regulated under RCRA and are not a hazardous waste though they may be regulated as a hazardous waste by state regulations (be sure to check with your state).

Since February 5, 1990 the TSCA regulations of 40 CFR 761 has required generators of PCB waste to use a uniform hazardous waste manifest for its off-site transportation.  The use of the uniform hazardous waste manifest for shipments of PCB waste requires the generator/offeror of the waste to complete it differently than they would for a hazardous waste regulated under RCRA.

The purpose of this article is to identify and explain the requirements of 40 CFR 761.207 for the use of the uniform hazardous waste manifest for the off-site transportation of PCB waste. (more…)