The History of the Hazardous Waste Manifest

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The Regulation of Hazardous Waste In the United States: 1634 to the Present

By: Victor Johnson, PE, Engineering Pathways

The sophistication today of computerized Hazardous Waste Management systems like Chemical Safety’s EMS software is amazing. These systems allow environmental professionals a wide range of tools to help assure environmental protection and personnel safety when dealing with hazardous substances. They also facilitate the necessary internal record keeping and regulatory reporting of activities dealing with these hazardous substances.

Since I have been a professional engineer in the hazardous waste management business since 1971, I am periodically asked “when and where did hazardous waste manifests begin?” I normally say that there was no specific individual person that invented manifests and no time specific date when they were first started. Their development has been the result of a continuous development and improvement process of many individuals over many years. For example, Chemical Safety Software first developed software related to hazardous waste management in 1991.

Many young environmental professionals and environmentally oriented individuals often feel that manifests were really not needed in the “old days” as hazardous wastes were just “randomly dumped” – with little or no regard to personnel and environmental safety. There is obviously significant truth to that statement. It is also true that responsible members of private industry and the governmental agencies that regulate industry have been working for decades on developing/improving hazardous waste manifests.

Historically, hazardous wastes were considered a subset of solid waste (i.e., garbage) and most regulations were aimed at traditional solid waste issues. Some of the first regulations dealing with the handling of waste materials occurred in 1634. Boston officials prohibited disposing of fish and garbage near the common landing. By the 1700’s, it also became evident that unsanitary conditions related to the handling of garbage caused major health impacts and more regulations followed. As time went on, more solid waste regulations were slowly developed – primarily on a local and State basis. The Federal role relating to solid waste management (including hazardous waste) generally was secondary to these local and State regulations.

The Modern Approach to Hazardous Waste

Fast forward to the early 1970’s in California, when the State realized that “lumping” hazardous wastes and solid wastes under one set of regulations was not the best way to insure environmental protection. One of the early multi agency and industry meetings to address this issue occurred on April 13, 1972. It focused on the transportation of hazardous waste and disposal of it and the proposed new regulations governing these activities. Numerous stakeholder presentations (including one of mine) were given at this meeting.

The new regulations after 1972 required manifests signed by the Producer, Hauler and Disposal Facility. I gave a paper at the Stanford Research Institute on October 23/24, 1974 showing the manifest my firm developed to meet the new regulations. Other disposal facilities developed similar manifests. In order to analyze for the various wastes, my firm and some others in California had to develop sophisticated chemical laboratories – which we were glad to do. These facilities gave our employees an extra degree of safety protection, helped protect our hazardous waste processing equipment, and allowed additional environmental protection.

The History of the Hazardous Waste Manifest

The movement towards manifests and more knowledge of the chemistry of the hazardous wastes within California ultimately led to the State developing a new law in 1977 (i.e., AB 1593). This law was California’s first comprehensive hazardous waste law. It effectively separated hazardous waste management away from solid waste management, which led to better hazardous waste management practices. I was proud to be an industrial sponsor for the proposed law as it went through the various legislative processes into finally becoming law.

In parallel, the Federal EPA was formed in December, 1970. It began having “Ad Hoc” meetings across the U.S. as part of its trying to figure out what the Federal role should be in hazardous waste management. One meeting was held in California on February 27/28, 1974. I presented a paper at it. Ultimately, the Federal Resource Conservation and Recovery Act (RCRA) was developed from the best practices of several States and passed in the 1976. Unfortunately, the hazardous waste regulations for RCRA did not become effective until 1980. It is interesting that RCRA followed the California format of having individual regulations for Hazardous Wastes (RCRA Subtitle C) and Non-Hazardous Solid Wastes (RCRA Subtitle D).

In summary, the hazardous waste manifest that we have today has been the result of the hard work of many individuals across the U.S. for over 40 years – both in the private sector and within government. Today’s manifests give the people of the United States a major tool for environmental stewardship and safe handling of hazardous wastes.

About the Author

Victor Johnson has over 49 years of experience in civil engineering, specializing the last 45 years in hazardous waste management engineering. He has worked both in the United States and internationally. He has headed teams that have successfully designed, obtained permitting for, and operated six commercial hazardous waste treatment and disposal facilities in Alabama, California, Louisiana, and Texas. Disposal methods at these facilities included secure chemical landfills, industrial landfarms, chemical processing, underground injection wells, and incineration. He also has designed and developed hazardous waste reclamation and detoxification facilities, managed emergency cleanup work, and provided remedial action responses at uncontrolled sites. He has acted as a liaison between the waste disposal industry and governmental regulatory agencies.

Recommended Additional Reading: GARBAGE: The Black Sheep of the Family by By Jon Roberts, with the Land Protection Division of the Oklahoma Department of Environmental Quality.

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