DOT Training Is Required For Persons Who Sign Hazardous Waste Manifests [49 CFR 172 Subpart H]
Shippers of hazardous materials must sign hazardous materials shipping papers before they offer their shipments for transport. The DOT's definition of hazardous material includes not only materials listed on the hazardous materials table and materials that display any of the DOT hazard classes, but also any hazardous wastes that are required to be listed on a hazardous waste manifest.
Although a hazardous waste transporter might complete hazardous waste manifests for you, you remain responsible for the accuracy of the information on the manifest. Before signing, you should check the information entered on the manifest to ensure that it is accurate and complies with the applicable DOT regulations.
When you sign a hazardous waste manifest, you certify that the materials listed on the manifest are properly classified, described, packaged, marked and labeled, and are in proper condition for transportation according to the applicable regulations ofthe DOT.
Therefore, because the person that signs the manifest is responsible for its accuracy, that person is classified as a hazardous material employee by the DOT. Hazardous material employees, including those participating in pre-transportation functions, must be trained per 49 CFR 172 Subpart H. Pre-transportation functions, as defined in 49 CFR 171.8, include completing or signing the hazardous waste manifest, as well as placing hazardous waste into containers, marking or labeling the containers, and loading or unloading the waste onto transport vehicles.
Hazardous waste generators are also subject to RCRA hazardous waste training requirements.
Environmental Resource Center, offers DOT Hazardous Materials Training in at locations nationwide and via online webcasts.