1. Introduction

SOP 3.5: Obtaining Manifest Signature Authorization

Contents

1. Introduction

2. Regulatory and contractual requirements

3. Manifest signature responsibilities

• 
  Generator HW ID number
  
• 
  Facility name and address
  
• 
  Shipper and transporter’s name, ID number, signature, and shipment date
  
• 
  Number of pages indicated on the first manifest page
  
• 
  That records include both the “two” and “three signature” manifest page(s) and Land Disposal Restriction (LDR) Form
  

• 
  HHW State-sponsored DOT three-year training cycle; see SOP 1.3 DOT
  
• 
  HHW State-sponsored DOT regulatory annual updates, including immediate instruction on safety and regulatory changes
  
• 
  HHW State-sponsored DOT Security and In-depth Security
  
• 
  DOT web-based and/or CD “Hazardous Materials Transportation Training Modules”
  
• 
  HHW State-sponsored initial and annual refreshers for Safety and Health, see SOP 1.4 HHW Training Requirements
  
• 
  HHW State-sponsored annual Hazard Categorization (Haz-Cat) as it relates to job functions that interface with commercial transporters including packaging and marking or labeling HW containers
  
• 
  RCRA training requirements, including review of completed shipping papers or manifests; see SOP 1.2 RCRA Hazardous Waste and 3.6 Manifests and Land Disposal Restrictions
  

4. Obtaining approval to sign manifests

1. 
   Training course records (e.g., class agenda, certification, test copies) for the previous 3 years, including:
   

• 
  Safety and Health
  
• 
  RCRA HW training requirements (e.g. shipping papers and/or manifests)
  
• 
  Haz-Cat as it relates to job functions that interface with commercial transporters (e.g., packaging, and marking or labeling HW containers)
  
• 
  DOT and DOT Security
  

2. 
   Site-specific, detailed, and written Program plans for each of the above training areas.
   

• 
  the purpose (Manifest Signature Authorization).
  
• 
  specific name(s) of Facility staff for which authorization is requested.
  
• 
  statements certifying that the person requesting manifest signature approval has:
  

1. 
   successfully completed HW training as it relates to manifesting requirements for specific job duties (Haz-Cat, Safety and Health, and DOT).
   
2. 
   been tested on the above training (see Attachment A of this SOP) and in accordance to this Programs’ specific and written plan(s).
   

Attachment A

Manifest Signature Authorization Sample Internal Exam Part 1

Packing, Storage, and Transportation Test

1. 
   When storing hazardous waste at this HHW Facility, responsible staff need to:
   
   1. 
      not worry about keeping incompatible materials away from each other since there is no danger of accidents.
      
   2. 
      use any type of lab packs and drums, as DOT-approved containers are not important.
      
   3. 
      stack drums several layers high to save space.
      
   4. 
      place closed-out containers in designated Facility storage areas.
      

2. 
   When preparing containers for shipment, labels are not required.
   
   1. 
      True
      
   2. 
      False
      

3. 
   Waste disposal paperwork shall be kept on file.
   
   1. 
      True
      
   2. 
      False
      

4. 
   There is no reason to use pH paper on items that appear to be acids.
   
   1. 
      True
      
   2. 
      False
      

5. 
   Labeling and marking of containers shall be completed:
   
   1. 
      when first opened.
      
   2. 
      the day before the hazardous waste contractor has scheduled a pick-up.
      
   3. 
      when closed out.
      
   4. 
      only when staff can’t remember what was placed into the container.
      

6. 
   All hazardous waste containers shall be:
   
   1. 
      inspected at least once a week for leaks.
      
   2. 
      be properly marked and labeled.
      
   3. 
      placed so all containers can be easily viewed (adequate aisle space).
      
   4. 
      placed anywhere in the Facility where there is extra room.
      
   5. 
      a, b, and c.
      

7. 
   When arranging for a pick-up of hazardous waste by the contractor, staff shall:
   
   1. 
      have a vague idea of what will be shipped out.
      
   2. 
      stack all containers outside a week ahead of time, so they are ready to go.
      
   3. 
      send lab pack inventories and number of bulk drums to the contractor a week prior to the pick-up date.
      
   4. 
      do nothing until the contractor arrives, since staff is unsure of how much truck space will be available.
      

8. 
   To prepare for the scheduled hazardous waste pick-up day, staff shall:
   
   1. 
      separate all containers into distinct categories.
      
   2. 
      stage containers to make it easier to load with a fork lift.
      
   3. 
      have sufficient container aisle space.
      
   4. 
      arrange containers so labels are visible.
      
   5. 
      all of the above.
      

9. 
   When lab packing hazardous waste, staff shall wear a full-face respirator at all times.
   
   1. 
      True
      
   2. 
      False
      

10. 
    It is necessary to open each container when lab packing hazardous waste.
    
    1. 
       True
       
    2. 
       False
       

11. 
    If a lab pack container requires an inventory, keep a copy:
    
    1. 
       in the Facility files.
       
    2. 
       on the container.
       
    3. 
       to forward to the disposal contractor.
       
    4. 
       in the solid waste as no packing lists are needed.
       
    5. 
       a, b, and c.
       

12. 
    The use of poly UN-approved drums is required for acid lab packs.
    
    1. 
       True
       
    2. 
       False
       

13. 
    Using liners in fiber lab pack drums is considered optional.
    
    1. 
       True
       
    2. 
       False
       

14. 
    Maximum allowed storage time for closed-out hazardous waste containers at this Facility is:
    
    1. 
       one month.
       
    2. 
       90 days.
       
    3. 
       180 days.
       
    4. 
       as long as needed.
       

15. 
    Program staff is responsible for ensuring correct shipping labels and/or markings are used.
    
    1. 
       True
       
    2. 
       False
       

16. 
    Class 8 corrosives can be loaded above or adjacent to ANY type of hazmat.
    
    1. 
       True
       
    2. 
       False
       

17. 
    To safely transport hazmat, staff shall ensure:
    
    1. 
       all labels are facing in the same direction
       
    2. 
       incompatible containers are segregated
       
    3. 
       each container is secured against movement
       
    4. 
       b and c
       
    5. 
       all of the above
       

18. 
    Common incompatible hazmat that should be segregated includes:
    
    1. 
       acids and bases
       
    2. 
       acids and cyanides
       
    3. 
       acids and pesticides
       
    4. 
       oxidizers and ignitables or flammables
       
    5. 
       oxidizers and pesticides
       
    6. 
       all of the above
       

19. 
    Shipping paper and/or manifest accuracy is the responsibility of:
    
    1. 
       the transporter shipping the hazmat
       
    2. 
       the receiving or end disposal facility
       
    3. 
       the generator
       
    4. 
       a and b
       
20. 
    Each class of hazmat is required to be transported in a specific type of container because:
    
    1. 
       it prevents incompatibility and/or chemical reaction problems
       
    2. 
       leaks will be contained
       
    3. 
       all of the above
       
    4. 
       none of the above
       

21. 
    A container is considered to be DOT approved for shipment if it displays the UN symbol and:
    
    1. 
       is compatible to the waste stored inside
       
    2. 
       is securely closed
       
    3. 
       is not leaking
       
    4. 
       b and c
       
    5. 
       all of the above
       

22. 
    A green colored label is used to indicate:
    
    1. 
       GO
       
    2. 
       Dangerous When Wet
       
    3. 
       Non-flammable gas
       
    4. 
       None of the above
       

Manifest Signature Authorization Sample Internal Exam Part 2

Hazardous Waste Categorization Test

1. 
   When receiving hazardous waste, staff shall:
   

1. 
   pH each container.
   
2. 
   segregate items into specific packing classes.
   
3. 
   place all waste on a cart and lab pack whenever it is convenient to do so.
   
4. 
   mix as many container contents together as possible to save space and money.
   

2. 
   It is okay to:
   
   1. 
      lab pack acids and bases together since they are both class 8 corrosive materials.
      
   2. 
      bulk unknown fluids into a solvent drum without prior testing.
      
   3. 
      bulk liquid dioxins into a solvent drum since they are also flammable.
      
   4. 
      lab pack small flammable items into a “Direct Charge” container rather than bulking them.
      

3. 
   When an UNKNOWN material is received, staff shall:
   
   1. 
      open the container immediately to see what is inside.
      
   2. 
      place the container into a waste category staff thinks is most correct.
      
   3. 
      ask the participant bringing in the item what the waste is.
      
   4. 
      smell contents to determine waste type.
      

4. 
   If picric acid is received, staff shall first:
   
   1. 
      open the container and bulk the contents with other acids.
      
   2. 
      call the local police, who will contact the bomb squad since it will definitely explode immediately.
      
   3. 
      visually inspect the container for crystallization and do not attempt to open.
      
   4. 
      shake the container vigorously and watch for a reaction.
      

5. 
   Hazardous waste items can be lab packed into any type of box, drum, or container.
   
   1. 
      True
      
   2. 
      False
      

6. 
   Acceptable absorbent packing materials may include:
   
   1. 
      crumpled up newspaper.
      
   2. 
      styrofoam shipping peanuts.
      
   3. 
      nothing.
      
   4. 
      vermiculite.
      

7. 
   All acids (organic and inorganic) may be packed together in the same lab pack.
   
   1. 
      True
      
   2. 
      False
      

8. 
   Keep water base separate from oil base while bulking paints.
   
   1. 
      True
      
   2. 
      False
      

9. 
   To document or track a lab pack or bulk container, staff shall:
   
   1. 
      assign a unique number.
      
   2. 
      enter the waste type, weight or size, and date shipped into the Facility drum logbook.
      
   3. 
      mark and/or label following DOT and hazardous waste regulations.
      
   4. 
      a, b, and c.
      

10. 
    Cyanide items shall be:
    
    1. 
       thrown into the solid waste since they pose no danger.
       
    2. 
       packed per individual type.
       
    3. 
       packed with other pesticides.
       
    4. 
       placed on product reuse/exchange shelves.
       

11. 
    When testing unknown wastes, if the pH paper indicates 0 to 1 pH, the item shall be:
    
    1. 
       packed as inorganic acid.
       
    2. 
       packed as organic acid.
       
    3. 
       packed as alkaline.
       
    4. 
       poured into the sewer since 0 to 1 pH is considered neutral.
       

12. 
    When selecting materials forbulking, the waste type needs to be:
    
    1. 
       pH of >5 and <10.
       
    2. 
       non pathogenic.
       
    3. 
       non reactive.
       
    4. 
       all of the above.
       

13. 
    When labeling waste containers, the primary label (four-inch sticker) is:
    
    1. 
       not needed.
       
    2. 
       placed anywhere you feel it should go.
       
    3. 
       placed on top only.
       
    4. 
       placed on top and one side of the container.
       

14. 
    To properly categorize a waste type for lab packing, staff shall refer to:
    
    1. 
       the Haz Cat manual.
       
    2. 
       Web reference sites such as www.hazard.com.
       
    3. 
       chemical reference book.
       
    4. 
       the State-contracted HW disposal company for help.
       
    5. 
       any of the above
       

15. 
    Only new drums/lab packs/boxes may be used as haz mat waste shipping containers.
    
    1. 
       True
       
    2. 
       False
       

16. 
    Hazmat employees MUST receive training at least every:
    
    1. 
       3 years
       
    2. 
       4 years
       
    3. 
       5 years
       
    4. 
       90 days
       

Attachment B

Manifest Signature Authorization

Sample Internal Exam Key for Attachment A