Frequent Questions

Can a generator authorize the initial transporter to add selected additional transporters to the hazardous waste manifest after they have signed the manifest and shipped the waste?

It is the sole responsibility of the hazardous waste generator to choose the sequence of transporters that will deliver a waste to the designated facility. The generator must approve any changes to the chain of transportation. A properly completed manifest identifies the full sequence of transporters that will conduct hazardous waste to a designated facility (Monthly Call Center Report Question; March 1996 (RCRA Online 13781)). 

EPA does not authorize haulers to make unapproved changes to the chain of transportation delineated on the manifest. In accordance with the manifest, transporters must deliver waste solely to the designated or alternate facility, the next designated transporter, or the designated export destination (Section 263.21(a)). Transporters who cannot deliver waste according to the generator's designation must contact the generator for instructions and must revise the manifest to reflect the approved changes to the prescribed chain of transport (Section 263.21(b)). Generators alone are responsible for identification of the complete chain of transportation and must, therefore, be apprised of and approve of all deviations from that plan.

Additional guidance regarding the requirement to list transporters on the manifest is available in the following documents: 

Memo, Cotsworth to Kotrosits; August 7, 1998 (RCRA Online 14279
Monthly Call Center Report Question; February 1998 (RCRA Online 14172
Memo, Shapiro to Dickhut; March 7, 1996 (RCRA Online 11953
Memo, Lowance to Engel; July 26, 1991 (RCRA Online 11630
Memo, Barley to Zak; April 30, 1987 (RCRA Online 11242
Monthly Call Center Report Question; March 1984 (RCRA Online 12192

These documents are available in the RCRA Online Database at the following URL: 

http://www.epa.gov/rcraonline

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