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1) Does HHW transported to our permanent HHW facility from temporary HHW <br />events and municipal load check programs need to be shipped on a uniform hazardous <br />waste manifest (and if not, could we just use a BOL)? <br />Unless specifically exempted (e.g., universal waste) then yes, HHW needs to be shipped on a <br />manifest (from a THHWCF) to a PHHWCF . <br />Note that load check programs located on the same site as the HHW facility does not need to <br />ship their waste under a Uniform Hazardous Waste Manifest if the load does not travel on a <br />public highway. <br />2) Can our permanent HHW facility serve as a TSDF and "kill" the manifests (sign on <br />line 20) as the receiving facility? <br />Yes a hazardous waste collection facility is a permitted offsite TSDF and can be listed as the <br />destination facility on a Uniform Hazardous Waste Manifest. As any other destination facility, <br />the TSDF signs off on the manifest. A manifest is never killed, it actually lives forever as a <br />public record. <br />3) If the answer to #2 is "yes," do these manifests then have to be mailed to the <br />State, just like we do with the manifests shipped from the permanent HHW facility? <br />A Uniform Hazardous Waste Manifest is a legal document. DOT requires that ANYTIME a <br />Uniform Hazardous Waste Manifest is used as a shipping paper that the directions be followed. <br />So the shipper/generator sends a copy to DTSC and the TSDF sends a copy to DTSC. <br />4) If reusable items are diverted from a temporary HHW event and we want to take <br />them back to our permanent HHW facility's reuse room, may we ship the items on a BOL <br />since we received the material and made the determination that it was not a waste (even <br />through the residential customer discarded it at the event)? <br />If the product meets the definition of a "reusable household hazardous product or material' as <br />defined in section 25218.1 (o) then it would not need to be manifested. It would probably not <br />require any shipping paper but as a business practice it is a good idea to have some sort of <br />documentation for what is on the truck. <br />5) Is there any law/section you can cite to verify, if HHWFs can in fact serve as <br />TSDFs for the purpose of accepting HHW? <br />22 CCR 67450.25(a)(2)(D). <br />