The LSPA presented the following compliance tip at the June Membership Meeting at the Hilton Hotel in Woburn, MA on June 13, 2019.  

COMPLIANCE TIP OF THE MONTH 

Do not ship any hazardous waste, either listed or characteristic, on a 21E Bill of Lading.  

The determination that a waste is not a listed hazardous waste cannot be made on the basis of laboratory data alone, nor is it enough to assume that due diligence has been conducted. The BOL requires an LSP Opinion that the waste has been adequately and properly characterized, which may require research into site history and process operations. Documentation of research to back up the determination that a waste is not a hazardous waste must meet the requirements of 310 CMR 30.007 (Accurate and Complete Record Keeping). See Interim Policy HW93-01.

Click here to view all published compliance tips. This document is also posted in the Members Only section of the website under Technical Resources.