FACT SHEET #20
MARCH, 2004
REVISION: THIRD

NORTHEASTERN UNIVERSITY PROCEDURE FOR SIGNING OFF ON MANIFESTS

GENERAL.
Northeastern University is registered with the U.S. Environmental Protection Agency (EPA) and Massachusetts Department of Environmental Protection (DEP) as a generator of hazardous waste. The Northeastern University EPA identification number is MAD 001423631. All hazardous waste generated at Northeastern University is required to be shipped out on a manifest when sent off campus for disposal. This manifest is an important part of the “cradle to grave management” of hazardous waste that is a corner stone of the Federal Resource Conservation and Recovery Act (RCRA). The Office of Environmental Health and Safety (EHS) will be the official repository for all Northeastern University hazardous waste manifests.

MANIFEST.
The typical manifest is made up of eight copies all of which are important in the tracking and management of hazardous waste. The manifest identifies such important things as who generated the waste, where is the waste going and what types of waste(s) are being shipped. The vender shipping hazardous waste will take the first five copies and will leave you copy six, seven and eight. Copy six must be mailed to the state agency where the hazardous waste is designated to be disposed of (identified in section nine of the manifest). Copy seven must be sent to the state agency where the hazardous waste is generated (Massachusetts Department of Environmental Protection). Copy eight must be retained by the generator of the hazardous waste (Northeastern University). When the waste is received at the facility designated to receive the waste, copy three that your vender originally took will be returned to you as the generator. If copy three is not received from the disposal facility within 35 days, an exception report must be filed with the Massachusetts Department of Environmental Protection outlining your attempts to locate this copy.

APPROVAL FOR SIGNING MANIFESTS.
Only Northeastern University personnel that have received training in hazardous waste management, and have reviewed and are familiar with this fact sheet, are approved to sign off on manifests. A current list of approved personnel is available and on file at EHS and the shared Q-drive Edds. Outside venders or venders that subcontract hazardous waste disposal services and list Northeastern University as the generator of the waste will not be allowed to sign off on manifests. Outside venders or venders that subcontract hazardous waste disposal service for waste they generate, can sign off on their own manifests and are responsible for their own paperwork.

MAILING AND FILING PROCEDURES.
Following the signing off of the manifest by the approved University personnel, copy six, seven and eight must immediately be turned over to the hazardous waste manager at EHS (229 FR). Hazardous Waste Regulations require copy six and seven be sent to the appropriate state agency within ten days. The hazardous waste manager will ensure that the appropriate copies are forwarded over to the state agency(s), copy three is received from the TSDF facility and the manifest(s) are appropriately filed.

WASTE MINIMIZATION.
The U.S. Congress has made waste minimization a national policy and goal of each waste generator. You, as an authorized person to sign off on manifests, have the responsibility to insure university personnel and venders you hire minimize the waste that is generated. Waste minimization has benefits such as decreasing your exposure to hazardous substances, protection of the environment, and the overall reduction in the cost of disposal which frequently can exceed the original cost of the chemical by 4 to 20 times.

LIABILITY.
Failure to abide by these regulations exposes the University to substantial penalties and sanctions. EHS has been advised by the Office of University Counsel that employees who fail to abide by these regulations also risk individual liability.

QUESTIONS.
If you have any questions, please contact the hazardous waste manager at EHS (x2769).