Here’s a question from a person with years of experience in the hazardous waste industry.  I know because he and I worked together years ago.  His latest question, from July 30th, 2015, is part of an ongoing conversation we’ve been having about the USEPA regulations for a hazardous waste transporter; and in particular, those regulations regarding the handling of hazardous waste in a 10-day transfer facility:

Is it necessary to have a different driver from the same company sign the RCRA Manifest as Transporter 2 when taking possession of it at a transfer facility from the driver who signed as Transporter 1?  I spoke to a lady from the USEPA who said “well sure you want the 2^nd transporter from the same company to sign, how else would you know who was driving” she was not real convincing. I spoke to <<name of state regulatory agency redacted>> and to a guy in <<name of state redacted>> and they both said no just the first driver from one company only needs to sign. If you come across anything please let me know. I will keep talking to people and looking things up. I would really like a concrete answer.

My response just a few hours later (7.30.15):

When in doubt.  Go to the regulations.

III. Instructions for Transporters Item 17. Transporters’ Acknowledgments of Receipt Enter the name of the person accepting the waste on behalf of the first transporter. That person must acknowledge acceptance of the waste described on the manifest by signing and entering the date of receipt. Only one signature per transportation company is required. Signatures are not required to track the movement of wastes in and out of transfer facilities, unless there is a change of custody between transporters. If applicable, enter the name of the person accepting the waste on behalf of the second transporter. That person must acknowledge acceptance of the waste described on the manifest by signing and entering the date of receipt.

Another satisfied, well…not a customer, just an old friend who happens to also be in the hazardous waste transportation and disposal industry.

Hey Dan,

Thanks for the quick help, I really appreciate it. The good news is it sounds like we have been doing it correct to date. It always drives me nuts when I get different answers from people. You are right, when in doubt go to the regs.

Thanks again,