Recently the NSSF featured this interview with one of our Senior Firing Range Engineers on the topic of Lead Impacted Waste Disposal-Proper Documentation & Manifests.
~ Let’s start off with an overview of what a manifest is and how it is used in disposal of lead contaminated hazardous waste at firing ranges?
Rob Anderson: A manifest is a document that tracks the disposal of waste, and it is important because as part of the “cradle-to-grave” process, it is the actual document that follows, records and serves as the final documentation for the cradle; in other words, when the lead-impacted waste originated with the generator, tracking all steps of the transportation process until it goes to the disposal facility which is also called the grave. It is a tool used by regulators to enforce regulations. It is also a tool used by generators to substantially prove that they are correctly following the rules. So, it’s a critical document for the range owner who is the generator of the waste. They can provide this to regulators who come to their facility and question their management practices.
A manifest will have the name of the generator, in this case, it would be the name of the firing range. There is a section where they identify the waste; not only the type of waste that you’re disposing of but also the quantity and the type of containers that are containing the waste.
As an example, a manifest could indicate that you have one drum of personal protective equipment/PPE, one cubic yard box of spent filters, one small five-gallon bucket of cleaning solvent used to clean the guns etc. These items would be laid out line-by-line detailing what the waste is.
Also, every manifest will have a line for the transporter. This is the person who is qualified to transport the type of waste that you document on the manifest. The transporter of hazardous waste must be a certified carrier which typically requires their DOT number.
~ Where do you get the hazardous waste forms? Is it something you order from the EPA as a download?
Rob Anderson: You can get what’s called a standard, blank or a generic hazardous waste and nonhazardous waste manifest. They will all have that specific list of information on all of them. You can get preprinted versions from a waste disposal facility. You can also contact a hazardous and nonhazardous waste disposal facility who can provide those to you as well.
~ Can you distinguish between a Bill of Lading and a Manifest?
Rob Anderson: Yes, that’s an excellent question because a bill of lading has very similar information that a manifest has in identifying who the waste is coming from, who is transporting it, and where it’s going. It also determines the type and quantity of the material. What it does not do, though, it does not recognize the nature of the material. A bill of lading is typically used for goods which hold a specific value, what we like to call “commercial value.” By definition, a bill of lading is not used in the transportation of waste. A bill of lading is involved in the transport of goods.
An excellent example for a firing range is when you have lead recovery being performed on your site. You are collecting a recoverable type of lead that is being put onto a truck and transported to a recycler. That is transported under a bill of lading because the material that’s being transported is a recyclable material. It’s considered a “good”. It holds a commercial value.
~ Let’s talk about the timeline, what is the actual timeline for getting the manifest initiated?
Rob Anderson: That’s a good point because this timeline can vary significantly based upon how well-prepared the range is for the management of their waste. Before you can even transport the waste off your site, you must initiate the process of submitting what is called a “profile” to the facility where it’s going to get disposed. The next step is receiving approval from that facility to have your waste disposed of, in the form of an approved profile. A range will identify if they have hazardous or nonhazardous wastes. This distinction typically is through a sampling process called TCLP. Toxicity Characteristic Leaching Procedure (TCLP) is a soil sample extraction method for chemical analysis used as an analytical method to simulate leaching through a landfill.
Remember, the most significant item to remember with waste disposal is the liability. The generator of the waste is liable for ensuring that their waste is being managed, transported and disposed of properly. If any of that is not performed and documented correctly, the liability always falls back on the generator, in this case, the range owner, even after the point of disposal!
However, during that process, the other people involved in the cradle-to-grave process also assume some liability. As an example, the transporter assumes a liability that they are looking at the material, they are determining it was adequately stored and then they are handling the responsibility of transportation from one location to the other. Therefore, it’s so important to make sure that you have an appropriately trained and permitted transportation company. The disposal company also holds a liability because this waste is going to be placed on their site. They will be held liable as well as the generator, the generator is never removed from their liability.
So, because the disposal facility has a liability, they also have the right to determine whether they want to accept your waste. The profiling process can take a matter of hours in some cases, or weeks/months in other cases, because again they must make sure you’re on top of all the steps and timelines for your paperwork.
You really can’t start the profile until you’ve generated the waste. A critical aspect to understand at this point is that the range needs to make sure that their waste is being properly stored and containerized on-site because it may have to sit anywhere from days to weeks or perhaps even months before getting disposed of.
As an example, if a contractor is recycling your lead in a smelting operation, they may be causing contamination of that property they are using, because of an inappropriate recycling process. You as the range owner can be held liable for the cleanup of THEIR property because it was YOUR materials that were transported to that site! It’s essential to make sure that you are having your recycled material sent to an appropriately vetted recycling facility and that you have documentation of the bill of lading as well as a certificate of recycling/certificate of destruction.
Regarding disposal, there is no other item than a manifest. So, if somebody shows you anything other than a standard manifest for disposal of your waste, they are not giving you appropriate documentation. A bill of lading is not an appropriate document for showing waste transportation and disposal. A cover letter from the owner of the company is not appropriate documentation.
It’s important to note that the waste that comes from your site is your waste. Do not let a contractor performing lead recovery at your site tell you that because they are doing the work, that they are the generator of the waste. That is not true.
MT2 Firing Range Services is the #1 largest most cost-effective nationwide professional indoor & outdoor firing range lead reclamation & maintenance contractor providing the highest value for your recycled lead.
Now in our 18th year in business, MT2 Firing Range Services is a recent Inc. 5,000 fastest growing company and is well-known industry wide for being the nation’s #1 largest professional provider of the full scale of outdoor/indoor firing range environmental/maintenance/construction services at over 2,000 ranges nationwide for Law Enforcement, Military and Commercial ranges in all 50 states.