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Pennsylvania Non-hazardous waste permits (November 22, 2002)

Pennsylvania Non-hazardous waste permits – Many people may have missed the fact that Act 90 became law on June 29, 2002. This legislation prescribes a new process for authorizing transporters to deliver municipal or residual waste within the state of Pennsylvania. Effective December 27, 2002, all such transporters must have received interim authorization to perform these services. This authorization comes at a price of $100.00 per truck, renewable annually.
HazMat Environmental Group has filed on a timely basis and is awaiting this authorization. Generators should take careful note to ensure that their carriers are properly permitted according to these new regulations. Disposal sites will not be allowed to accept non-hazardous waste from un-permitted trucks after December 26, 2002, and may have to report to the state the details of any attempted deliveries by un-permitted vehicles.
This is further complicated by the fact that trucks may contain both hazardous and non-hazardous waste on the same shipment. In that case, the carrier must be notified in advance, by the party requesting the transportation service, that the load contains both hazardous and non-hazardous waste, so a properly-permitted vehicle can be assigned. The generator should also refrain from listing non-hazardous waste on the hazardous waste manifest. That way if undisclosed, co-mingled non-hazardous waste is discovered on an un-permitted vehicle, the non-hazardous portion can be off-loaded onto a properly permitted vehicle.
This whole situation raises additional cost considerations for carriers, not only in the permitting but in the inevitable re-handling of non-hazardous portions of shipments that is bound to occur when the generator is unsure of the new regulation and handling procedures. HazMat Environmental Group is forced to add these permitting costs to each shipment of non-hazardous waste which delivers into a Pennsylvania facility. This will cover the costs to permit our vehicles on an as-needed basis, since complete registration of our fleet, which exceeds 400 vehicles, is cost prohibitive. In addition, we will have to charge for the miles traveled and labor involved to sort out non-hazardous portions of waste shipments that were not disclosed to us at the time of placing the order.
Once again, a state has caught us up in a web designed for other purposes. Pennsylvania is primarily aiming at the out-of-state refuse haulers but the language of the legislation has ensnared us along with them, and there’s nothing we can do about it. All we can do is alert you to this new exposure, work with you to deal with it and pass on the new charges that have been created by virtue of it.
For more information we encourage you to contact Nancy Copelin, our Compliance Director, at (716) 827-7200 or ncopelin@hazmatinc.com

 

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