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printreg, June, 2003
Do Lab Samples of Haz Waste Need Manifest

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From:Debra Jacobson(djacobson@istc.illinois.edu)
Date: Wed, 04 Jun 2003 07:58:08

Although you do need to maintain chain of custody paper work with lab samples, waste manifests for lab samples are not necessary. See below for more details and the on-line regulations.
Debra Jacobson

Does hazardous waste sent to a laboratory for testing have to be manifested?

No, the waste is excluded from RCRA regulation as long as it meets the lab sample exclusion requirements in 40 CFR 261.4 (d). This exclusion requires, in part, that the sample be packaged according to applicable shipping requirements (e.g., USDOT or USPS), and that the laboratory return the unused portion of the sample to the generator. Additional details for qualifying for this exemption are provided in 40 CFR 261.4 (d)(2).

The regulations at §261.4(d) exclude from RCRA regulation small samples of wastes that are sent to a laboratory for the sole purpose of determining hazardous waste characteristics or composition. Although the regulations do not specify a size limit, EPA policy limits the sample size to 1 gallon (46 FR 47426; 25 September 1991).

To access 40 CFR 261.4 (d) on-line, visit http://www.access.gpo.gov/nara/cfr/cfr-retrieve.html#page1

Title: 40
Part: 261
Section: 4

Source: "reg of the day" listserv operated by Tammy Silverthorne @ the Environmental Resource Center

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