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Interpretation Response #00-0114 ([New Village Industrial Park] [Ms. Daniel G. Fox])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: New Village Industrial Park

Individual Name: Ms. Daniel G. Fox

Location State: NY Country: US

View the Interpretation Document

Response text:

June 2, 2000

 

Ms. Daniel G. Fox                Ref. No. 00-0114
Director of Training
New Village Industrial Park
60 Commerce Drive
Buffalo, New York 14218-1040

Dear Ms. Fox:

This is in response to your letter dated April 11, 2000, requesting clarification on the hazardous waste manifest requirements under §172.205(c) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask whether it is permissible for the shipper/generator to prepare, sign and date a manifest in accordance with 40 CFR Part 262 at the time it is offered for transportation, even though the initial carrier may not sign and date the manifest to accept the waste until three or four days later.

Section 172.205(c) requires that the shipper/generator sign and date the manifest at the time the shipment is offered for transportation and the initial carrier at the time the shipment is accepted.  The HMR do not prohibit the use of different shipper/generator and initial carrier dates on the manifest form.  The Uniform Hazardous Waste Manifest (EPA Form 8700-22 and 8700-22A), is required by the U.S. Environmental Protection Agency (EPA).  Therefore, you should contact your EPA regional office or state environmental office or EPA's RCRA Hotline at 800-424-9346 regarding different shipper/generator and initial carrier dates on the manifest.

I hope this answers your inquiry.

Sincerely,

Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards

172.205

Regulation Sections