What are Handling Codes on a U.S. Hazardous Waste Manifest?
A hazardous waste manifest is a document that must travel with hazardous waste when it gets moved off-site.
Copies of this document are given to someone at each leg of the transport process:
- The generator of the waste (your business).
- Transporter of the waste.
- The treatment, storage, and disposal facility (TSDF).
Each manifest contains two types of codes: a waste code, (or codes) and a handling code.
A waste code identifies the type of waste streams being disposed of. The waste generator usually determines which waste codes to use, however, most generators contact their hazardous waste disposal company for assistance.
A handling code classifies what the TSDF is going to do with the waste. They describe “the type of hazardous waste management system used to treat, recover, or dispose of a hazardous waste” (EPA).
The manifest process creates a start to finish (cradle to grave) tracking of the entire hazardous waste disposal process.
Unfortunately, while most generators understand waste codes, many waste generators don’t know what handling codes mean and why they’re important to the waste management process — and their business.
Today, we will walk you through:
- What handling codes signify
- Why they’re important to your business
- What happens after transport and disposal is completed
- Why you need to keep all of this paperwork
Let’s delve into what you need to know about hazardous waste handling codes.
What the Handling Codes Signify
Each handling code consists of the letter “H” followed by three digits.
Together, these handling codes are used to identify how each waste stream will be (or has been) disposed of.
These codes are broken into four Management Method Groups:
- Reclamation and Recovery
- Destruction or Treatment Prior to Disposal at Another Site
- Transfer Off Site
Reclamation and Recovery involves the retorting, smelting, and chemical break down of metals, distillation and extraction of solvents, and other recovery methods.
Destruction or Treatment Prior to Disposal is the largest group, and involves incineration, chemical reduction, cyanide destruction, biological treatment, evaporation, sludge treatment, and more.
Disposal involves land treatment or application, sending waste to a landfill, a deep well or underground injection, and/or discharge to a sewer.
Finally, Transfer Off Site involves “the site receiving this waste stored/bulked and [transferring] the waste with no treatment or recovery (H010-H129), fuel blending (H061), or disposal (H131-135) at the receiving site.”
Each waste management method is assigned a unique handling code. There are over 40 specific handling codes that can be assigned to a manifest.
You may be wondering, “How does this concern me? Doesn’t the TSDF handle all of this?”
The answer is yes, they do. But how they handle it is extremely important to you, especially if your business is concerned about its carbon footprint and environmental impact.
Why Hazardous Waste Handling Codes are Important to Your Business
It’s imperative that you pay attention to and understand the handling codes on your manifest.
First, there are different fees that you pay for recycling and disposal. You pay a minimal fee for a manifest that included recycling. So, this code confirms to you that you got the treatment you paid for.
Otherwise, you would have no way of knowing if you paid more for an expensive and environmentally sustainable treatment, but got a cheaper and lower quality alternative.
When you get the manifest back after its cradle to grave trip, you get a chance to make sure everything was handled the way you wanted it to be. Since the waste generator is ultimately responsible for the disposal of the waste streams, the manifests act as your insurance policy, so to speak, if the DTSC comes knocking on your door for an audit.
Second, your business may have a company mandate to reduce its carbon footprint — to recycle or dispose of your waste in the most efficient and environmentally friendly way possible.
To do this, you will need to know which handling codes signify that your waste has been treated or disposed of in a sustainable manner.
If you don’t understand what the handling codes mean, you won’t know whether you’re contributing to or minimizing your carbon footprint.
What Happens After Transport and Disposal is Completed?
After transport and disposal, you should receive paperwork back from the recycling facility (TSDF).
This will be sent from the recycling facility back to you to signify that the disposal has been carried out to completion.
This is when you should check the handling codes to make sure that 1) you got the treatment you paid for, and 2) the treatment complied with your efforts to be as sustainable and environmentally friendly as possible.
Why You Need to Keep This Paperwork
The Department of Toxic Substances Control (DTSC) might do periodic audits of your facility.
They will want to see your paperwork from the generation, transport, and disposal process. Match up all the copies of the manifests with completed signatures and staple together.
Many generators will have a folder called “Open,” that contains all the manifests waiting to be completed. Once they receive the final manifest copy from the disposal facility, they attach all the manifest copies together and move them into a folder called “Closed.”
We suggest that you save these manifests in your closed folder for at least 5 years.
The hazardous waste transport process is of dire importance.
It helps the EPA keep track of which waste is coming from where, and it helps you make sure it has been disposed of in the manner you paid for.
For waste generators that want to do the right thing, understanding what the handling codes truly mean to your business is an important process that should not be overlooked.