HAZARDOUS WASTE MANAGEMENT 102: WASTE PACKAGING AND

TRANSPORTING

Presented by: Racheal Mani, Kel-Ex Agencies, A Div. of ICC

• It must be packaged and transported safely in compliance with the Hazardous Waste Regulation (HWR) and if applicable the Transportation of Dangerous Goods Regulation (TDG).

Waste stream is correctly classified… now what?

• The HWR defines hazardous waste as waste which are dangerous goods (Class 2, 3, 4, 5, 6, 8,& 9) as per the TDG that are no longer used for their original purpose and those waste streams which because of their toxic or reactive nature must be handled or disposed of properly to prevent harming people or the environment.

Relationship Between HWR and TDG

• TDG applies to dangerous goods (Class 1-9 and specifically product) which are being offered for transport, in transport or handled for the purpose of transportation.

Relationship Between HWR and TDG

• If the waste stream is classified as a hazardous waste and falls within the hazard class of 2, 3, 4, 5, 6, 8, & 9 of the TDG then that waste stream must be transported in accordance with the TDG which includes packaging, marking/labeling, and documentation along with all parts of the TDG.

What does that mean?

• There are some specific hazardous waste streams which do not fall under the TDG classification but are considered hazardous waste in the province of BC such as Leachable Toxic Waste and Waste Oil.

Some Exceptions

• Get your TDG certification if you are a generator, an agent acting on behalf of the generator, carrier, or receiver if you are dealing with TDG regulated waste.

• Ensure the TDG certificate is valid (36 months).

Certification

• As a generator (shipper) of the TDG regulated hazardous waste you must be TDG certified to be able to offer for transport which includes signing off on movement document (manifest) that contain TDG regulated waste.

Generators or Agents for Generators

• In BC carriers are required to obtain a license to transport (LT) to be able to transport hazardous waste.

• Along with a whole bunch of information the carrier must write and PASS an exam based on knowledge of the HWR regulatory requirements which includes TDG.

• This is an addition to having a valid TDG certification.

Carriers

• TDG certified to accept TDG regulated waste.

• Receivers may become shippers when facilities are sending hazardous waste to end disposers.

Receivers

Packaging

• All waste, hazardous or not, must be packaged to prevent leak or release during handling and transport.

• Packaging must be compatible with the waste stream.

• Generators must comply with Part 5 (Means of Containment) of the TDG regulation for TDG regulated waste streams.

Packaging

TDG regulated waste

Small Means of Containment (MoC)

• ≤ 450 L capacity• Based on performance (typically single use)• TP14850 : Small Containers

Packaging: Small vs. Large

Large Means of Containment (MoC)

• > 450 L capacity• Based on design (intended for re-use)• TP14877 : Rail Containers• Various CSA (Canadian Standards Association)• Various CGSB (Canadian General Standards Board)

Packaging: Small vs. Large

• Standardized packaging is not required; however, general rules of packaging apply.

• For example, bulk load of leachable toxic waste (soil) should be loaded in a lined bin and transported with a cover (tarp).

Packaging: Hazardous but not TDG

• Certain waste streams require specific packaging requirements for storage/disposal which correlates to transportation requirements.

Management of Specific Hazardous Waste

• Liquid PCB waste must be stored in 16 gauge steel drums (205 L capacity).

• Asbestos must, for dry airtight containment techniques, be packaged in 6 mil plastic bags placed within a non-reuseable drum and then sealed, or packing in a 6 mil plastic bag placed within a second 6 mil plastic bag and then sealed.

Example: PCB and Asbestos

• Identifying the content inside the packaging.

Marking and Labeling

TDG regulated hazardous waste has specific marking and labeling requirements as per Part 4 (Dangerous Goods Safety Marks) of the TDG regulation.

Marking and Labeling

Small means of containment• Proper shipping name• Hazard labels for each primary and subsidiary class • Identification number

Marking and Labeling – Small MoC

• Large means of containment• Placards are required to be displayed on all 4 sides

Marking and Labeling - Large MoC

• For non-TDG hazardous waste, the HWR requires the shipping name of the hazardous waste be displayed on smalls means of containment.

• However, most generators and/or receivers have their own specific requirements in addition to the HWR.

Marking and Labeling – Non TDG

• For example, some generators require all material leaving their site include company specific information such as a job number.

• Many receivers require a waste profile/disposal code to be displayed on the packaging prior to receiving the waste at their facility.

Marking and Labeling – Non TDG

• Inner packagings in a labpack require the shipping name of the waste stream.

• The outside of the labpack must contain the shipping name followed the word “labpack”.

• If the labpack contains TDG regulated material then TDG requirements apply.

Marking and Labeling for Labpacks

Transportation

• All hazardous waste shipment must be accompanied by a manifest along with other applicable transport documents.

• In BC, these manifests are purchased from the BC Ministry of Environment and each manifest has a distinct tracking number.

• The manifest is the key link in the “cradle to grave” management of hazardous waste.

Documentation

Hazardous Waste Manifest/Movement Document

Generator completes Section A

Carrier completes Section B

Receiver completes Section B

BC 12345-6

• In addition to manifests there are other supplement documents which can accompany shipments of hazardous waste.

Supplement Documents

• Multiple Different Waste Supplement – used when there are more than 4 different waste streams or you run out of room on the actual manifest.

Multiple Different Waste Supplement

• Multiple Carrier Supplement – used when more than 1 carrier is involved in transporting the hazardous waste.

Multiple Carrier Supplement

• Multiple Consignor Supplements – used when picking up the same waste stream but from different consignors (i.e. waste oil).

Multiple Consignor Supplements

Manifest Distribution

TDG Regulated Manifests

• HWR requires generators to comply with TDG documentation requirements if the hazardous waste shipment is TDG regulated.

For example, effective July 15, 2015 • TDG required all documents accompanying a dangerous goods shipment include the consignor certification which meant the generator must manually add the statement on the manifest if the shipment contained TDG waste stream.

Consignor Certification

• The sequence in which the TDG shipping information must appear on a document is UN no., shipping name, hazard class, and packing group followed by other relevant information which meant manual entry of this sequence on the manifest.

Sequence

• Equivalency Certificates allows a person to conduct an activity in a way not consistent with the TDG.

TDG Equivalency Certificate

• TDG regulated hazardous waste shipments may also be accompanied with a TDG Equivalency Certificate.

• For example: TDG regulated labpacks require an Equivalency Certificate. There are terms and conditions to adhere to such as using a liner bag to package a labpack.

Labpack Equivalency Certificate

• Federal notices are required to ship hazardous waste/recyclable into or out of Canada:

• Export and Import Hazardous Waste Notice

• Export and Import Hazardous Recycle Notice

Import and Export of Hazardous Waste

• TDG placards must be displayed on all 4 sides of a large means of containment for shipments of TDG regulated hazardous waste when applicable.

• Non-TDG regulated hazardous waste do not require placards.

Placards

• TDG has recently updated Part 8 (Reporting Requirements).

• The BC Spill Reporting Regulation is applicable to a release or discharge into the environment.

Reporting Requirements

• Lack of knowledge in the HWR;• Misclassification of waste;• Shipping TDG regulated hazardous waste without complying with TDG;

• Missing information on the manifest and/or supplements;• Manifest are not distributed within the time frame; • Assuming a carrier’s LT applies all types of hazardous waste.

Common Issues

• BCEIA website;• BC Ministry of Environment website;

• Hazardous Waste Legislation guide (updated October 2016);• Manual for Completion B.C’s Hazardous Waste Manifests and Supplementary

Forms;• Transport Canada website;• Your competent waste services provider:• Your TDG training provider;• Your environmental consultant.

Available Resources

Questions?