A Comprehensive Checklist for Packing & Shipping Hazardous Waste

In the past, treatment, storage, and disposal facilities (TSDFs) often assisted hazardous waste generators in correcting packaging or shipment errors. However, with the tightening of EPA regulations and increased legal and financial risks, most TSDFs will now reject any shipment that does not meet strict compliance standards set forth by the state or Feds.

To help hazardous waste generators avoid costly mistakes, this guide provides a detailed checklist to follow before sending hazardous waste to a TSDF. Below is a brief overview of the key steps, with further details following:

Identify and characterize the hazardous waste.
Determine the applicable EPA hazardous waste codes.
Ensure proper container selection and maintenance.
Label containers according to EPA’s regulations.
Mark and label containers in accordance with DOT’s standards.
Complete an e-Manifest or paper manifest or Bill of Lading.
Arrange for DOT compliant transportation to the TSDF.

1. Identify and Characterize the Hazardous Waste

The EPA mandates that hazardous waste generators create a Hazardous Waste Profile (previously called a waste characterization profile) for any hazardous waste disposal. This profile must detail the chemical composition of the waste and be submitted to the TSDF before shipment for approval. Without this documentation, the TSDF is legally prohibited from accepting the waste.

Providing a thorough breakdown of the waste’s constituents percentage adding up to 100% allows the TSDF to confirm its ability to process the material appropriately, whether through landfill disposal, incineration, or further treatment. Additionally, it ensures the facility has adequate capacity and personnel for your waste at the time of arrival.

2. Determine the EPA Hazardous Waste Codes

The EPA classifies hazardous waste using a coding system that dictates how it must be managed and disposed of. Below are the four primary lists:

P List: Highly toxic hazardous wastes from commercial chemical products.
F List: Hazardous waste from common industrial processes.
K List: Industry-specific hazardous waste.
U List: Waste from off-specification commercial chemicals.

3. Select and Maintain Proper Containers

Hazardous waste containers must be:

Structurally sound and in good clean condition.
Compatible with the waste they contain.
Securely sealed to prevent leaks or spills.

4. Label Containers According to EPA Requirements

EPA regulations state that all hazardous waste storage containers must:

Be clearly labeled with “Hazardous Waste.”
Display the start date of waste accumulation.
Indicate the waste classification (e.g., toxic, reactive, ignitable, or corrosive).

5. Mark and Label Containers to DOT Standards

DOT regulations require that hazardous waste containers:

Be labeled with the statement: “HAZARDOUS WASTE—Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.”
Display the generator’s name, EPA ID number, and manifest tracking number.
Feature appropriate DOT hazard class labels.

6. Complete an e-Manifest and/or paper manifest for driver

Since June 2021, hazardous waste shipments require an electronic manifest (e-Manifest) instead of or in addition to paper documentation. This form tracks the waste from its point of origin to the TSDF, ensuring regulatory compliance.

7. Arrange EPA-Compliant Transportation

Hazardous waste transporters must have an EPA ID number and adhere to strict federal and state regulations. It is the generator’s responsibility to ensure the transporter is:

Properly insured, licensed, and permitted.
Trained in hazardous materials handling.
Equipped with compliant vehicles and containment methods.

Final Thoughts

While this checklist provides a comprehensive overview of hazardous waste packing and shipment regulations, compliance is complex and varies based on waste type, transport method, and regulatory changes. The EPA, DOT, and FMCSA all have separate but overlapping rules governing hazardous waste.

For businesses that generate hazardous waste infrequently, or for those unfamiliar with the nuances of EPA and DOT regulations, working with an experienced hazardous waste disposal service such as the staff at ADCO can ensure compliance and avoid costly penalties.

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