United States
              Environmental Protection
              Agency
              Solid Waste and
              Emergency Response
              (OS-305)
              Washington, DC 20460
EPA/530-SW-89-022
September 1989
xvEPA
Managing and Tracking
Medical wastes
A Guide to the Federal Program
for Transporters
              Printed on recycled paper.

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Introduction
 In response to the growing public concern over mismanagement of medical wastes,
 Congress enacted the Medical Waste Tracking Act. The Act charges the Environmental
 Protection Agency with responsibility for implementing a two-year demonstration
 medical waste tracking program that will help determine the best medical waste
 management procedures for the future. The program's goal is to find an  effective
 means to ensure that regulated medical wastes get from their point of generation to
 their point of disposal.

 Generators of regulated medical wastes will be part of the new demonstration tracking
 program in the States of Connecticut, New Jersey, New York, and Rhode Island, and
 the Commonwealth of Puerto Rico. Transporters and facilities that store, treat, destroy,
 and dispose of these wastes will also be part of the program.

 This guide offers general information about the tracking program (Section 1) and
 specific instructions for transporters of regulated medical waste (Section 2). Section 2
 includes  requirements for transporters, including owners and operators of transfer
 facilities that carry regulated medical waste generated in a participating state. It also
 includes requirements for the vehicles used by transporters. Separate guides in this
 series are provided for generators and  facilities that treat, destroy, and dispose of
 regulated medical wastes.

 This guide describes the federal program only. It is designed to help  transporters
 comply with the program. For more complete information, transporters should refer to
 "Standards for the Tracking and Management of Medical Waste," interim final rule (40
 CFR Part 259).  In addition, states participating in the program have their own  rules for
 managing medical waste. For further assistance, addresses and phone numbers of EPA
 Regional Offices and participating state programs are listed in Appendix A.

For additional copies of Managing and Tracking Medical Wastes or a copy of 40 CFR Part
259, call the RCRA Hotline at (800) 424-9346 or, in Washington, D.C., 382-3000.

The cooperation of all participants in the management of regulated medical waste will
assure the success of this important demonstration  program and reduce public
exposure to the waste.

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 Contents


 SECTION 1: The Medical Waste Tracking Program	\
 Waste Managers Participation 	              !
 Regulated Medical Wastes 	              2
 Pre-Transporting Procedures 	            2
 Tracking Regulated Medical Wastes	        2
 The Waste Management System	             4
     Generators  	                       /,
     Transporters	                        c
     Treatment, Destruction, and Disposal Facilities	 5

 SECTION 2: A Detailed Guide for Transporters of Regulated Medical Waste
 Profile of a Transporter 	                    ^
     Transporters Subject to All Requirements	 6
     Special Exceptions  	                  ^
 Notifying EPA and the State  	            7
 Vehicle Requirements  	                    7
 Tracking Medical Wastes  	           8
     Obtaining Forms	                8
     Accepting Waste Shipments	  ^	g
     Delivering in the United States	.10
     Delivering Outside the United States  	..'... 10
     Consolidating Shipments	       JQ
     Rail Shipments	                    12
 Recordkeeping	                        j~
 Reporting 	                         -p
     Transporter Reports  	                12
     Exception Reports  	  	12
     Discrepancy Reports	          13
     Additional Reports  	                13
 Medical Waste Transporter Checklists	   14

 Glossary	                             -,Q

 List of Figures
 Figure 1. Tracking Form 	           3
 Figure 2. Medical Waste Tracking System	 4
 Figure 3. Shipping Regulated Medical Waste Accompanied by a Tracking Form  ... 9
 Figure 4. Consolidating Shipments	   n

Appendix A EPA Regional Offices and Participating State Programs  	20
Appendix B Packaging, Labeling, and Marking Requirements  	21
Appendix C Transporter Notification Instructions and Form 	22

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S  ction 1:
The Medical Waste Tracking Program
Waste Managers
Participation
                          In response to public concern over the mismanagement of medical wastes, the Medical
                          Waste Tracking Act was enacted in the fall of 1988. The law directs the Environmental
                          Protection Agency (EPA) to establish a two-year demonstration program for tracking
                          medical wastes.

                          Under this law, EPA has issued regulations entitled "Standards for the Tracking and
                          Management of Medical Waste" (40 CFR Part 259). The regulations list the medical
                          wastes to be tracked and cover standards for separating, packaging, and labeling
                          medical wastes before  sending them for treatment or disposal. The results of the
                          demonstration program are intended to help determine whether such a program
                          should be extended nationwide.
                             The Medical Waste Tracking Act amends the Resource Conservation and Recovery Act
                             (RCRA) by adding Subtitle J. It defines medical waste as "... any solid waste which
                             is generated in the diagnosis, treatment, or immunization of human beings or animals,
                             in research pertaining thereto, or in the production or testing of biologicals. ..."
Participating in the demonstration program are the States of Connecticut, New Jersey,
New York, and Rhode Island, and the Commonwealth of Puerto Rico. The regulation
is an interim  final rule.  It will be in effect for  two years, until June  22, 1991. In
Connecticut, New Jersey, and New York, the program is effective beginning June 22,
1989; in Rhode Island and Puerto Rico, the program is effective beginning July 24,1989.

The demonstration program involves only regulated medical wastes generated in one
of the states participating in the program, even when these wastes leave the state. The
program sets up a system for tracking the waste from the generator to the disposal site.
A tracking form that accompanies this  waste is signed  and a  copy is retained by a
representative of the waste generator  and each  transporter,  transfer station,  and
treatment, destruction, and disposal facility handling it. When the final disposer—the
destination facility—accepts the waste, a copy of the signed tracking form is returned
to the generator. In this way, the generator is assured that the waste was received for
disposal. The  tracking system includes "exception" and "discrepancy" reporting to
alert EPA and the states if wastes are not being handled properly.

To minimize contact  with regulated medical wastes by workers, handlers, and the
public,  the program includes  specific  requirements  for segregating, packaging,
labeling, marking, and storing medical wastes before they are shipped to another site
for treatment,  destruction, or disposal. Other requirements include recordkeeping,
reporting, and enforcement. EPA will evaluate the success  of the program and report
the results to Congress.

This booklet is intended to help transporters of regulated medical wastes generated in
the participating states comply with the federal rules. Transporters must also follow
rules  required by  the individual states and  should check with  state officials  for
clarification of state rules. While participating states use the same basic tracking form as
EPA's, some states might regulate more  wastes or  require special permits or licenses.
Participating states are authorized to enforce this program.

The demonstration program includes medical waste  generators  in participating states;
transporters of those wastes; and owners and operators of treatment, destruction, and
disposal facilities that manage waste  generated in participating states, even if their
facilities are  located in  nonparticipating  states. Similarly, the program  includes
transporters carrying regulated medical wastes from participating states, even if the

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Regulated Medical
Wastes
Pre-Transporting
Procedures
Tracking Regulated
Medical Wastes
wastes are then taken to nonparticipating states. The program includes vessels and
transporters that take medical wastes to shore from ships docked in participating
states. Federal facilities generating regulated medical wastes in participating states are
also covered under this program.

Medical wastes affected by the pilot program include
•  cultures and stocks of infectious agents.
•  human blood and blood products.
•  human pathological wastes, including those from surgery and
  autopsy.
•  contaminated animal carcasses from medical research.
•  wastes from patients isolated with highly communicable diseases.
•  all used sharp implements, such as needles and scalpels, and certain
  unused sharps.
These regulated medical wastes fall into two categories: untreated or treated. The
Glossary provides detailed descriptions of these medical wastes.

The demonstration program focuses on wastes that have  been improperly managed
and are most likely to pose a substantial threat to human health and the environment.
However, any additional waste that a health care professional believes may pose a risk
should be handled as a regulated medical waste.

Mixtures of regulated medical waste and general trash are regulated as  medical waste.
Mixtures of regulated medical waste and hazardous  waste are usually regulated as
hazardous waste.  However, if medical waste is mixed with hazardous waste, which
falls under the small quantity hazardous waste exemption, then the  waste mixture
must be tracked as medical waste under this program.

Regulated medical wastes that  are to be transported to an off-site facility for treatment
or disposal  must be properly  prepared for shipping.  First,  the wastes must  be
separated from general trash, and then sharp items, fluids, and other medical wastes
must be separated from each other to the extent possible.  They are then packaged to
prevent tearing, breaking, or leaking during shipping and  handling. (See Appendix B
for packaging, labeling, and marking requirements.)

Packages are to be labeled and marked to identify the contents of the package and the
generator and transporter of the waste. In addition, stored wastes must be maintained
to prevent them from coming into contact with workers or the public.

At the core of the medical waste demonstration tracking system is a MEDICAL WASTE
TRACKING FORM (see Figure 1). This form must accompany each off-site shipment
that weighs 50 pounds or more. Shipments from generators of less than 50 pounds a
month may be  combined  onto  one tracking form by the transporter. Generators,
transporters, and treatment, destruction, and disposal facilities are responsible for
filling in, forwarding, and retaining a copy of this form  for their records. Figure 2
illustrates how the medical waste tracking system works.

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MEDICAL WASTE TRACKING FORM
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1 . Generator's Name and Mailing Address
3. Telephone Number ( )
5. Transporter's Name and Mailing Address
EPA Med. Waste ID No.
I I I I I I I I I I I I I
8. Destination Facility Name and Address
2. Tracking Form Number
4. State Permit or ID No.
6. Telephone Number
( )
7. State Transporter Permit or ID No.


9. Telephone Number
( )
10. State Permit or ID No.
11 . US EPA Waste Description 1 2. Total No.
Containers
a. Regulated Medical Waste (Untreated)
b. Regulated Medical Waste (Treated)
c. State Regulated Medical Waste
13. Total Weight
or Volume



14 Special Handling Instructions and Additional Information
15. Generator's Certification:
Under penalty of criminal and civil prosecution for the making or submission of false statements, representations, or
omissions, I declare, on behalf of the generator 	 	
that the contents of this consignment are fully and accurately described above and are classif ed, packaged, marked, and
labeled in accordance with all applicable State and Federal laws and regulations, and that I have been authorized, in writing,
to make such declarations by the person in charge of the generator's operation.
Printed/Typed Name Signature
Date
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INSTRUCTIONS FOR COMPLETING MEDICAL WASTE TRACKING FORM
Copy 1 — GENERATOR COPY: Mailed by Destination Facility to Generator
Copy 2 — DESTINATION FACILITY COPY: Retained by Destination Facility
Copy 3 — TRANSPORTER COPY: Retained by Transporter
Copy 4 — GENERATOR COPY: Retained by Generator
As required under 40 CFR Part 259:
1 . This multicopy (4-page) shipping document must accompany each shipment of regulated medical
waste generated in a Covered State.
2. Items numbered 1-14 must be completed before the generator can sign the certification. Items 4, 7,
10, 1 1c, & 19 are optional unless required by the State. Item 22 must be completed by the
destination facility.
For assistance in completing this form, contact your nearest State office or Regional EPA office, or
call (800) 424-9346.
16. Transporter 1 (Certification of Receipt of Medical Waste as described in items 1 1 , 12, & 13)
Printed/Typed Name Signature
1 7. Transporter 2 or Intermediate Handler
(name and address)
EPA Med. Waste ID No.

Date
18. Telephone Number
( )
19. State Transporter
Permit or ID No.
20. Transporter 2 or Intermediate Handler (Certificat on of Receipt of Medical Waste as
described in items 1 1 , 1 2, & 1 3)
Printed/Typed Name Signature
Date
21 . New Tracking Form Number (for consolidated or remanifested waste)
22. Destination Facility (Certification of Receipt of Medical Waste as described in items 1 1 , 12, & 13)
fj Received in accordance with items 1 1 , 12, & 13
Printed/Typed Name Signature Date
(If other than destination facility, indicate address, phone, and permit or ID no. in box 14.)
23. Discrepancy Box (Any discrepancies should be noted by item number and initials)

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                           GENERATOR
                           TRANSPORTER/TRANSFER
                           FACILITY
                            DESTINATION FACILITY
                            A generator of more than 50 Ibs. per month who ships off
                            site or a generator of less than 50 Ibs. per month who ships
                            more than 50 Ibs. in a shipment.
                                                        Generator initiates Tracking Form, completes Generator
                                                        information section, signs Generator's certification.
                            Transporter  verifies  accuracy  of Generator information,
                            signs Tracking Form, gives Generator signed copy, and
                            retains all other copies.
                                                         I
                                                        OR
                                                         t
                                      Transporter may consolidate loads and initiate a
                                      new Tracking Form.*
                             Destination (final disposal) facility accepts waste, signs
                             Tracking Form, gives one copy to the Transporter, keeps
                             copy for its own records, and returns a completed copy to
                             the initiator (party that fills in Generator block) of the Form.
                            'Initiators of Tracking Forms become Generators in effect under this Tracking System.

                            FIGURE 2. All medical waste shipments required to be accompanied by a tracking form
                            are tracked from generator to final disposal, or destination facility.
The Waste Management
System
Because it is helpful for those involved in the demonstration program to understand
the roles of generators, transporters, and facilities, their roles are presented here.
                            Generators

                            A person or institution located in a participating state, generating 50 pounds or more of
                            regulated medical waste monthly and shipping it off site, is  fully covered by the
                            demonstration program. These generators must separate, package, label, mark, and
                            track medical wastes according to the regulation. Generators often hire transporters to
                            provide many of these services, including supplying them with appropriate tracking
                            forms.

                            Generators producing and shipping less than 50 pounds a month must also prepare
                            their wastes properly for shipment. They may use a log to account for wastes, however,
                            instead of a tracking form.

                            On the other hand, generators that dispose of waste on site or in the sewer system are
                            not covered by the requirements of this program. Generators that treat and destroy
                            waste on site,  such as  by  incineration,  are  subject to certain reporting and
                            recordkeeping requirements. Wastes that are treated and destroyed or disposed of on
                            site or in sewers are  not counted as part of the 50 pound monthly limit. All medical
                            wastes—even those treated,  destroyed,  and  disposed on site—must be stored
                            properly.

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 Transporters

 Transporters must notify EPA of their intention to comply with the program to be
 allowed to accept regulated medical wastes  for transport. EPA maintains a list of
 transporters who have notified  EPA of their intent to transport regulated medical
 wastes generated  in each participating  state.  This list  is available to generators
 Transporters must follow rules  governing their vehicles and addressing tracking'
 recordkeepmg  and reporting of waste shipments. They must also make sure that
 wastes they p,ck up have been properly prepared for shipping and  that the trackine
 rorm is accurate.                                      no                   5

 Treatment, Destruction, and Disposal Facilities

 The  demonstration tracking program rules apply to  owners  and  operators  of
 treatment  destruction, and disposal facilities receiving  regulated  medical wastes.
 These facilities include incinerators, landfills, and treatment operations that grind
 steam sterilize, or treat the waste with disinfectants, heat, or radiation.            '

 Like generators and transporters, treatment, destruction, and disposal facilities must
 keep track of medical wastes and maintain records. Facilities must send a signed copy
 of the tracking form  back to  the generator or initiator of the tracking form when
 the wastes have been accepted for disposal. The facility  owners or operators must
investigate any discrepancies between the accompanying  papers  and the shipments
they receive; if, after investigation, there is still a discrepancy, they must report it to
hPA and the generator state agency.
                                   Generator packaging
                                   medical waste
                                                              Transporter vehicle
                                              Steam sterilizing,
                                              or autoclaving,
                                              before disposal

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Section 2:
  A Detailed Guide for Transporters of Regulated
  Medical Waste
Profile of a Transporter
  This section presents instructions for transporters of regulated medical wastes to help
  them comply with the federal programs. Detailed checklists are included.

  All  transporters of regulated  medical  waste  generated in participating  states are
  covered by the medical waste demonstration program. Transfer facilities that handle
  regulated  medical wastes,  generators that  transport  their  own  wastes   and
  intermediate  handlers that carry regulated  medical wastes are also subject to the
  transporter requirements in this program.

  Transporters  must determine  if they intend  to handle  regulated medical wastes
  originating in participating states.  If so, they must notify EPA  of their  intention
  Transporters need  to know which of the medical wastes they transport are regulated
  and what special  handling procedures apply. All transporters carrying  regulated
  medical waste generated in participating states are affected by the program, even if
  they carry waste to a nonparticipating state.

  Transporters Subject to All Requirements

  In general, transporters of regulated medical waste must comply  with  all applicable
  requirements of the regulation.  They must
 • notify EPA of their intent to handle regulated medical waste
   originating in a participating state.
 • agree to follow rules governing the vehicles they use.
 • make sure that the wastes are properly packaged, labeled, and
   marked.
 • comply with rules for tracking, recordkeeping, and reporting of waste
   shipments.
 Transporters may also be
 • required to initiate tracking forms.
 • subject to state requirements for permitting, licensing, and registering.

 Special Exceptions

 Generators transporting their own  medical  wastes should  refer  to  Managing and
 Tracking Medical Wastes: A Guide to the Federal Program for Generators. In addition,  the
 following transporters are subject to exceptions to the regulations:

 Transporters may arrange with generators of less than 50 pounds of regulated medical
 waste a month to  accept  individual shipments  of less than 50 pounds without
 preparing a tracking form. In these instances, the transporter and  the generator are
 required to maintain logs  containing shipment information. The  transporter must
 carry this log in the vehicle. Before transferring  custody of these logged wastes  the
 transporter must initiate a tracking form, as a surrogate generator, and  attach a log
 sheet describing the individual shipments documented on the tracking form.

Transporters may consolidate individual shipments of less than 220  pounds  by
initiating a new tracking form with combined  total quantity information. They must
then attach  a  log sheet describing the individual shipments  that comprise  the
combined load.

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Notifying EPA and the
State
Vehicle Requirements
 Transporters must notify both the EPA and the participating state before handling
 regulated medical wastes. If transporters plan to handle waste from more than one
 participating state,  they must submit separate notification forms for each of those
 states. Transporters are required to send the original and one copy of each notification
 to EPA; another copy of the transporter notification must be sent to the director of the
 waste management agency in the participating state the transporter is notifying (see
 Appendix A). Appendix C includes a transporter notification form and instructions for
 notifying EPA and the state.

 EPA will  assign each transporter that notifies the Agency an EPA Medical Waste
 Identification Number. After receiving this number, transporters must enter it on the
 tracking form in either Box 5 or 17, as required (see Figure 1).

 Vehicles used to transport regulated medical waste must
 • have a fully enclosed, leak-resistant, cargo-carrying body, such as a
  cargo compartment, box trailer, or roll-off box.
 • protect waste from mechanical stress or compaction.
 • have a cargo-carrying body that is in good sanitary condition and that
  can be locked.
• have the following identification on the two sides and back of the
  cargo-carrying body in letters at least three inches high: name of the
  transporter; transporter's state permit or license number, if any; the
  words MEDICAL WASTE, REGULATED MEDICAL WASTE or
  INFECTIOUS WASTE.
                         Vehicle identified as a transporter of medical waste

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Tracking Medical Waste    The tracking form ensures that the transfer of each shipment of regulated medical
                          waste is documented and reaches its destination. Therefore, it is crucial for every
                          transporter to comply with tracking form requirements.
                                                                       Transporter filling out a tracking form
                         Obtaining Forms

                         Transporters are responsible for providing the generator with the proper form when
                         waste is destined for a disposal site in another participating state.  In addition, they
                         may assist generators by acquiring the appropriate forms based  on the following
                         hierarchy:

                         •  from the participating state to which the waste is to be ultimately
                           delivered. In this case, the transporter is required to provide tracking
                           forms.
                         •  if that state does not provide tracking forms, from the state in which
                           the waste was generated.
                         •  if the generator state does  not print the tracking form, from other
                           sources including reproduction of Figure 1 from this booklet or 40 CFR
                           Part 259, Appendix I.


                         Accepting Waste Shipments

                         Transporters may not accept a shipment from a generator of more than 50 pounds a
                         month unless the shipment is accompanied by a completed tracking form signed by the
                         generator.  Figure 3 diagrams the tracking system for transporters.

                         Transporters may not  accept shipments of less than 50 pounds  from facilities
                         generating less than 50 pounds a month unless the material has been logged. Logged
                         shipments, however, may only be accepted from the original generators, not from a
                         transporter.

                         Before accepting for transport any regulated medical waste that is accompanied by a
                         tracking form, the transporter must
                         • ensure that the waste is properly packaged, labeled, and marked (see
                          Appendix B).
                         • certify that the tracking form accurately reflects the number and total
                          weight of the packages.

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 Then the transporter must

 • sign and date the tracking form, indicating acceptance of and
  responsibility for the regulated medical waste.
 • return a signed copy of the tracking form to the generator before
  leaving the generator site.
 • be sure that the tracking form remains with the regulated medical
  waste while in transit.
    GENERATOR SITE
  Transporter signs tracking
    form, accepting RMW
    shipment, and gives
   generator a signed copy
                                                                DESTINATION FACILITY
                           Transporter transports RMW from
                           generator site to destination facility
                         Tracking form accompanies shipment
Transporter delivers shipment to
 facility; facility representative
 signs tracking form, accepting
  RMW shipment, and gives
  transporter a signed copy
  Key

  Waste Transport

  Tracking Form
                               Facility mails copy of signed
                              tracking form back to generator
FIGURE 3. Shipping regulated medical waste accompanied by a tracking form.
                                           Transporter inspecting
                                           shipment of medical waste
                      Signing tracking form  N
                   accepting waste shipment  **>*

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                        Delivering in the United States
jating tracking forms


   • retain one copy of the signed and dated tracking form
   • give the remaining copies of the tracking form to the acceptine
    transporter, mtermediate handler, or destination facility  P§

   Delivering Outside the United States




  • sign the tracking form and verify that the waste has been delivered
  • retain one copy of the signed tracking form

  ' gen" "tor.'6™™"8 ^ °f *e ^"Z form' ^ mai1'  «° the

 Consolidating Shipments

 Transporters may consolidate multiple shipments of less than 9?n     A    ^ •






• name of each generator.
• generator state permit or identification number. If the generator state
  address" "** ^ " identi&atio" nun.be™, then & ^Ltof

•  date the regulated waste was originally shipped by the generator
•  quantity of each category of regulated medical waste (number of
  contamers and/or weight in pounds) shipped by each generator
  names and state permit or identification numbers of all previous
                                                           the
                   accepted for disposal. The


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 copies  of both  forms  together  and  sends  them,  within  15  days,  to  the  original
 generator. In this way, the generator knows that the waste was accepted for disposal. If
 a transporter consolidates or remanifests shipments, the transporter must also comply
 with Exception Reporting requirements.
 Consolidating shipments of less than 50 pounds
     GENERATOR SITE
                                         TRANSPORTER
                                                                         DESTINATION FACILITY

Transporter signs tracking
form, accepting RMW
shipment, and gives generator
a signed copy
A


Waste
transport
Tracking form
shipment


Transporter consolidates
shipments by preparing a
consolidation log, initiating a
tracking form for the
consolidated load, and
attaching a copy of the log to
the new form. The new form's
number is entered on the
generators' original form(s)
It
Waste
transport ^
New tracking
form and log
accompany
consolidated
shipment


Transporter delivers consolidated
shipment to facility; facility
representative signs tracking form,
accepting RMW shipment, and gives
transporter a signed copy


            Transporter attaches copy of signed form it
            receives from facility, to generator's original
               and mails both copies to generator
                               Facility mails copy of signed
                             tracking form back to transporter
                                 who initiated the form
     Key

     Waste Transport

     Original Tracking Form

     New Tracking Form
                The flow charts above illustrate the movement of the tracking form for consolidated
                shipments of regulated medical waste. The top diagram shows the documentation
                process for consolidation of shipments of less than 50 pounds, which are accepted
                by the transporter unaccompanied by a tracking form. The bottom diagram shows
                the documentation process for consolidating, or remanifesting, shipments of less
                than 220 pounds, which are accompanied by tracking forms initiated by the original
                generator.
Consolidating/remanifesting shipments of less than 220 pounds
     GENERATOR SITE
  Transporter signs generator's
  log, accepting RMW shipment,
 and compiles a truck log noting
       that transaction
 Waste
transport
                                         TRANSPORTER
                                                                         DESTINATION FACILITY

Transporter consolidates
shipments by preparing a
consolidation log, initiating a
tracking form for the
consolidated load, and
attaching a copy of the log to
that tracking form
4
Waste
transport
Tracking form
and log
shipment

Transporter delivers consolidated
shipment to facility; facility
representative signs tracking form,
accepting RMW shipment, and
gives transporter a signed copy
•

                                                       Facility mails copy of signed
                                                      tracking form back to transporter
                                                         who initiated the form
FIGURE 4. Consolidating shipments
                                                                                               11

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Recordkeeping
Reporting
Rail Shipments of Regulated Medical Waste

In those instances where regulated medical wastes generated in a participating state
are transported by rail, special rules apply. For further information see 40 CFR Part 259,
Subpart J. Rail shippers accepting regulated medical waste from a non-rail transporter
must
• sign and date the tracking form, acknowledging acceptance of the
  regulated medical waste.
• return a signed copy of the tracking form to the transporter.
• forward at least three copies of the tracking form to the next non-rail
  transporter, if any; or to the intermediate handler or destination
  facility, if the shipment is delivered to that facility by rail; or to the last
  rail transporter designated to handle the waste in the United States.
• ensure that the load is accompanied by shipping papers containing all
  tracking form information, except permit or license numbers and
  generator certification.
• retain one copy of the tracking form or rail shipping papers.

Transporters  are required  to keep for three  years  copies of all tracking  forms;
 transporter logs; Exception and  Discrepancy Reports, if  filed;  and semi-annual
 reports. In addition, for waste accompanied by a tracking form and consolidated by the
 transporter onto another tracking form, the transporter must also retain for three years
 • the transporter copy of the generator-initiated tracking form.
 • a copy of the transporter-initiated consolidation tracking form signed
  by the intermediate handler or destination facility.
 • a copy of each required transporter report, described below.

 Transporters must  submit  reports every six months for the two-year duration of the
 program, as well as Exception and Discrepancy Reports, if necessary.


 Transporter Reports

 If  a  transporter accepts regulated  medical waste directly from  a generator in a
 participating state or transports waste generated in a participating state during the six-
 month reporting period, the transporter must submit a report summarizing those
 activities for each state. These reports must be submitted to the chief of the EPA Waste
 Characterization Branch and the  director of the waste management agency in the
 affected state. Each report contains information about the transporter, each generator
 from which waste was accepted, and each facility to which waste was delivered.

 Reports are due on the 45th day following the end of the six-month reporting period,
 summarizing information from tracking forms and transporter  logs.  For  further
 information,  refer  to 40 CFR Part 259,  Appendix III.  For copies of the form  call the
 RCRA Hotline at (800) 424-9346; in Washington, D.C., call 382-3000.


 Exception Reports

 Transporters who have initiated a tracking  form must also  meet the Exception
 Reporting requirements of the tracking program. If a signed tracking form bearing the
 signature of the disposal facility representative is not received within 35 days from the
 12

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date the regulated medical waste was accepted from the original generator, the initiator
of the tracking form must try to locate the waste. If, after 45 days, a signed tracking
form is still not received, then an Exception Report must be filed by the transporter
with the state and the EPA Regional Administrator on day 46. The Exception Report
consists of a letter describing the efforts and the results of such efforts to determine the
disposition of the waste and a legible copy of the original tracking form. A copy of this
report is to be retained for three years.

Discrepancy Reports

Transporters are generally not required to  file Discrepancy Reports.  However, if a
transporter learns after accepting waste that there is a  discrepancy, the transporter
should try to resolve the problem. A discrepancy exists  if a tracking form indicates a
difference between the waste that is accepted and that which is documented on the
accompanying tracking form. For example, the number of containers or  the waste
categories might be  inconsistent  or  the  package might  leak. Other types  of
discrepancies include the presence of broken, torn, or leaking  packaging; waste
unaccompanied  by  a tracking form, where one  is required;  or  an  incomplete  or
improperly completed tracking form. If such discrepancies are discovered and they
cannot be resolved, they must be reported in writing within 15 days to the appropriate
EPA Regional Administrator and the generator's state agency. A legible copy of the
tracking form  or shipping papers  is to be  attached. Discrepancy Reports must  be
retained for three years.

Additional Reports

The Administrator  may require  transporters  to furnish additional information
concerning the quantities and management methods of regulated medical waste.
                                                                            13

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                            Regulated Medical  Waste Transporter Checklist
                            Do these regulations apply to you?
                            	  Does your company participate, or intend to participate, in the transport of
                                     medical wastes?
                            	  Does your company intend to continue or initiate such activities for medical wastes
                                     that have been generated in one of the following states: Connecticut, New Jersey,
                                     New York, Rhode Island and Puerto Rico?
                            Is your company authorized to transport regulated medical waste?
                            	  Has your company submitted the following notification information to the Waste
                                     Characterization Branch, EPA Headquarters for each participating state that may
                                     be a source of medical waste you will handle?

                                     	  Company name, mailing address and EPA Hazardous Waste
                                              Identification Number (if applicable).
                                     	  Name, address, and telephone number for each site in that state from
                                              which medical waste transport vehicles will operate.
                                     	  State identification or permit number(s), if applicable, required for
                                              handling medical or infectious waste.
                                     	  Statement signed by a corporate official or owner or operator: "I certify,
                                              under penalty of criminal or civil prosecution for the making or
                                              submission of false statements,  representations, or omissions, that I have
                                              read, understand and will comply with the regulations at 40 CFR
                                              Part 259, issued under authority of Subtitle J of the Resource
                                              Conservation and Recovery Act."

                            	  Have you provided the appropriate waste management agency in each of those
                                     participating states with a copy of the EPA notification for that state?
                            	  Has your company received a unique EPA-assigned Medical Waste Identification
                                     Number?
                            	  Are you entering your Medical Waste Identification Number as required on the
                                     Tracking Form?
                            	  Do individual states in which you handle or transport regulated medical waste
                                     require other licensing or permitting requirements that may affect your company's
                                     medical waste transportation activities?

                            Does your company ensure that the following requirements are met for all its vehicles that
                            transport regulated medical wastes?
                            	  The cargo-carrying body (i.e., cargo compartment, boxtrailer, roll-off box, freight
                                     container) is fully enclosed, leak resistant, and capable of being locked.
                            	  The cargo-carrying body is maintained in good, sanitary condition.
                            	  The cargo-carrying body is secured and locked if the vehicle is left unattended.
                            	  The vehicles have the following identification information on both sides and rear of
                                     the cargo-carrying body, in letters at least 3 inches in height:
                                     (1) Company name
                                     (2) Company's state permit or license number, if state issues and requires one, or
                                        else company's address
                                     (3) The words MEDICAL WASTE, INFECTIOUS WASTE,  or REGULATED
                                        MEDICAL WASTE
                            	  Waste is not subjected to mechanical stress or compaction during loading and
                                     unloading, or during transit.
                            	  Regulated medical waste is not transported in the same container as other solid
                                     waste unless the combined material is to be managed as regulated medical waste.
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Does your company manage transportation of regulated medical wastes in accordance with
all applicable regulations, including

	  Ensuring that all accepted shipments of regulated medical waste are properly
          labeled, marked, and accompanied by proper paperwork?

	  Ensuring that all shipments, except for those of less than 50 pounds which are
          from generators of less than 50 pounds per month,  are accompanied by a properly
          completed Tracking Form?

Do you

	  Ensure that the generator is provided with the proper Tracking Form if the waste is
          to be disposed of in another participating state?

	  Ensure that the Tracking Form is properly completed and that the information on
          the form accurately represents the number and/or total weight and waste
          classification of the packages being accepted for transport?

	  Make sure generator provides information on designated treatment or disposal
          facility before signing the form?

	  Visually inspect all packages of regulated medical waste to be accepted for
          transport to ensure they are properly packaged, labeled, and marked?
	  Ensure that the "Generator Certification" block has  been signed by an authorized
          representative of the generator facility before accepting that shipment?

	  Sign and date the Tracking Form, acknowledging acceptance of the waste from the
          generator and return the generator's copy before leaving the generator's premises?
	  Ensure that the Tracking Form accompanies the waste it covers at all times during
          transport?

When delivering waste to another authorized transporter, intermediate handler, or
destination facility, do you

	  Make certain all regulated medical waste documented on the accompanying form
          is transferred to the next party and, if any discrepancies are apparent, attempt
          to resolve them with the recipient of the documented waste (i.e., counting
          containers, reviewing all relevant logsheets, etc.)?

	  Obtain the signature and acceptance date from an authorized representative  of that
          party?

	  Retain the transporter's copy of the Tracking Form signed by the receiving party?
	  Give the remaining copies of the completed Tracking Form to the accepting
          transporter, transfer or treatment or disposal facility?

When consolidating regulated medical waste shipments of 50 to 220 pounds onto a single
Tracking Form prior to transferral to another transporter, intermediate handler, or
destination facility, do you

	  Complete the Tracking Form as both generator and initial transporter,  signing both
          certification blocks (blocks 1 through 16)?

	  Record in a transporter's log the following information for all loads that are being
          consolidated onto the single Tracking Form?

          	  Names of generators
          	  Generators' addresses or unique identification numbers
          	  Original Tracking Form number(s) or dates waste was originally
                   accepted from generators

          	  Quantity of waste by waste type (treated, untreated, or state-regulated),
                   by number of containers and/or weight in pounds, from each generator
          	  New Tracking Form number that covers consolidated waste
                                                                                   15

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                             	  Attach a copy of the transporter's log sheet to the new Tracking Form?
                             	  Attempt to resolve any apparent discrepancies with the recipient of the
                                       documented waste (i.e., recounting containers, reviewing all relevant logsheets,
                                       etc.)?

                             	  Obtain the signature and acceptance date from an authorized representative of the
                                       receiving transporter or facility?

                             	  Retain the generator's and transporter's copies of the completed Tracking Form for
                                       recordkeeping?

                             	  Give the remaining copies of the completed Tracking Form to the authorized
                                       recipient (accepting transporter, intermediate handler or destination facility)?

                             	  Within 15 days of receipt of the treatment/disposal facility-signed Tracking Forms
                                       that you initiated,  attach a copy to the generator's original form and return both
                                       copies to the generator(s)?

                             When handling shipments of less than 50 pounds  of regulated medical waste from
                             generators of less than 50 pounds per month, which are documented through use of logs,
                             do you

                             	  Ensure that all regulated medical waste to be accepted for transport is properly
                                       packaged, labeled, and marked?

                             	  Sign and date the  generator's log, which  contains the shipment information
                                       (transporter name, state identification number or address, and quantity of waste
                                       shipped), after determining that information is accurate?

                             	  Record in your transporter's log the following information?

                                       	  Names of generators

                                       	  Generators' addresses or unique identification numbers
                                       	  Date waste was originally accepted from generators

                                       	  Quantity of waste by waste type  (untreated, treated or state regulated),
                                                by number of containers and weight in pounds, from each generator
                             	  Before transfer of the "logged" waste to the next authorized party, initiate a
                                       Tracking Form which will account for all consignments of logged materials which
                                       are on board the vehicle? Do you fill out the form as both "Generator" and
                                       "Transporter," signing both certification blocks (blocks 1 through 16)?

                             	  Attach a copy of the appropriate log sheet(s) to the completed Tracking Form?
                             When delivering the waste to another authorized transporter, intermediate handler, or
                             destination facility, do you
                             	  Make certain all material documented on the accompanying form is transferred to
                                       the next party? If any discrepancies are apparent, do you attempt to resolve them
                                       with the recipient of the documented waste (i.e., recounting containers, reviewing
                                       all relevant logsheets, etc.)?
                             	  Obtain the signature and acceptance date from an authorized representative of the
                                       party accepting the waste?
                             	  Retain both the generator's and transporter's copy of the signed Tracking Form for
                                       recordkeeping?
                             	  Give the remaining copies of the completed Tracking Form to the authorized
                                       recipient?
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 Do you understand the following recordkeeping requirements?

          ^T^^f ^St maintdin rec°rds of a11 '^actions involving regulated medical
          waste handled for a period of 3 years from the date it accepts such waste
          Records must include copies of

                   Generator-initiated Tracking Forms signed by company employees.
                   Tracking Forms your company has initiated for consolidation of
                   shipments or documentation of "small quantity" logged waste.
          	  Transporter's log information recorded for all small quantity logged
                   shipments and consolidation transactions.               ^   &&
          	  Reports submitted by your company including Exception, Discrepancy,
                   and Transporter (semi-annual) Reports.                       F   y

Do you understand that

	   Transporter Reports documenting your waste handling activities are required?
	   Transporters may be required to file Exception Reports and, if a discrepancv is
          discovered after accepting waste, a Discrepancy Report?        aiscreP*ncy is

                              ***** transPorters to P™vide additional information, if
                                                                               17

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                               Glossary
  Cultures and Stocks
  Pathological Wastes
  Human Blood and Blood
  Products
  Sharps
  Animal Waste



  Isolation Wastes



  Unused Sharps
  Following are the classes of regulated medical wastes and a description of each.

  Cultures and stocks of infectious agents and associated biologicals including: cultures from
  medical and pa hological laboratories; cultures and stocks of infectious agents from research
  ^1^UH    laboratOTf s' TwaSteS, fr°m  the P^duction of biologicals; discarded live and
  cultures    VaCCmeS;           "*        ^ deVlCeS USed tO tra"sfer'  inoculate, and mix

                    WaSteS/ induding tissues' organs, and body parts and body fluids that are
                     er °r aUt°PSy " ^ ^^ Procedures' and specimens of body fluids

  Liquid waste human blood; products of blood; items saturated and/or dripping with human
  blood; or items that were saturated and/or dripping with human blood that are now caked ™h
  dried  human  blood including  serum, plasma, and other blood components, and their
  containers, which were used or intended for use in either patient care, testing and laboratory
   nSS "*     deVel°Pment °f Pharmaceuticals. Intravenous bags are alsoLluded in this
                               and heir
  Sharps that have been used in animal or human patient care or treatment or in medical, research
  or ^industrial laboratories. These include hypodermic needles, syringes (with or w thout the
  attached needle), pasteur pipettes, scalpel blades, blood vials, needles with attached tubing!
  and culture dishes (regardless of presence of infectious agents). Also included are other types^

  and covenr°slips    ^ 8laSSWafe that Were in contact with infectious agents, such as used slides
 hn' b°dy.Parts' and bedding of animals that were known to have
 been exposed to infectious agents during research (including research in veterinary hospitals),
 production of biologicals, or testing of pharmaceutical.                            *

 Biological waste and discarded materials contaminated with blood, excretion, exudates  or
 secretions from humans who are isolated to protect others from certain highly communicable
 diseases, or isolated animals known to be infected with highly communicable dise^Ss

                     / dlSCarded 8harPS: hypodermic needles,  suture needles, syringes, and
                              The following terms are defined here to address the management of medical wastes. They may b
                              different from those federal definitions used for solid or hazardous waste.
 Biologicals



 Blood Products

 Body Fluids


 Central Collection Point

 Container



 Decontamination

 Destination Facility

 Destroyed Regulated
 Medical Waste
 n                     livln? orSanisms and their Products, including vaccines, cultures, etc
 research     "** " diagn°SmS' ionizing,  or treating humans o? animals, or in related

 Any product derived from human blood, including but not limited to blood plasma, platelets
 red or white blood corpuscles, and other derived licensed products, such as interferon
 Liquid emanating or derived from  humans and limited  to blood;  cerebrospinal,  svnovial
 pleural, peritoneal, and pericardial fluids; and semen and vaginal secretions.       synovia1'

 A location where  a generator consolidates  regulated medical waste brought together from
 original generation points prior to its transport off-site or its treatment on-site.

 h^HF^TK16 ^^^ ^ Whi€h J material is St0red' transPorted, disposed of, or otherwise
 i^ems that ar, ^^^ ^hen Ascribing the packaging requirements, does not include
 items that are regulated medical waste.

 The process of reducing or eliminating the presence of harmful substances, such as infectious
 agents, so as to reduce the likelihood of disease transmission from those substances
 The disposal facility, the incineration facility, or the facility that both treats  and  destroys
 regulated medical waste to which medical wastes are shipped.                     Destroys

Regulated medical waste that has been ruined, torn apart, or mutilated through
as thermal treatment melting  shredding, grinding, tearing, or breaking,

                                       but has not yet
18

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 Destruction Facility
 Facility
Generator
infectious Agent
                            	•		

   A facility that destroys regulated rned"                            "		





  SSS^^J^^^Wast!-!;-.---^
                                                                      'than
                                                                       each
ntermediate Handler


aboratory
indfill


iedical Waste




i-site
SM'nal Generation Point

'rsized Regulated
«cal Waste


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Appendix A
EPA Regional Offices and Participating State Programs
Participating State
Programs
EPA Regional Offices
Connecticut Department of
Environmental Protection
Solid Waste Management Unit
State Office Building
165 Capitol Avenue
Hartford, CT 06106
(203) 566-5847
(Region I)

New Jersey Department of
Environmental Protection
Division of Solid Waste Management
401 East State Street, CN 414
Trenton, NJ 08625
(609)984-7840
(Region II)

New York State Department of
Environmental Conservation
50 Wolf Road
Albany, NY 12233
Tracking form: (518) 485-8394
Other inquiries: (518) 457-3254
(Region II)
                Rhode Island Department of
                Environmental Management
                9 Hayes Street
                Providence, RI 02907-5003
                (401) 277-2771
                (Region I)

                Puerto Rico Environmental
                Quality Board
                Box 11488
                Santurce, PR 00910
                (809) 722-0439
                (Region II)
Region I
State Waste Programs
Branch
JFK Federal Building
Boston, MA 02203
(617) 573-5758

Region II
Air and Waste
Management Division
26 Federal Plaza
New York, NY 10278
(212) 264-5166

Caribbean Field Office
(809) 729-6920

Region III
Waste Management
Branch
841 Chestnut Building
Philadelphia, PA 19107
(215) 597-2842
Region IV
Hazardous Waste
Management Division
345 Courtland Street, N.E.
Atlanta, GA 30365
(404) 347-3016

Region V
RCRA Activities
230 S. Dearborn Street
Chicago, IL 60604
(312) 353-9510

Region VI
Air and Hazardous Materials
Division
1445 Ross Avenue
Suite 1200
Dallas, TX 75270
(214) 655-6652

Region VII
RCRA Branch
726 Minnesota Avenue
Kansas City, KS 66101
(913) 236-2856
Region VIII
Waste Management Division
999 18th Street, Suite 500
Denver, CO 80202
(303) 293-1496

Region IX
Toxics and Waste
Management
215 Fremont Street
San Francisco, CA 94105
(415) 974-8388

Region X
Waste Management Branch
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-6501
20

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                                            the
°f receiPt of *e regulated medical
                                waste.
                                                                    21

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Appendix C             Transporter Notification Instructions and  Form
    General Information:

    AUTHORITY:
    This information is required by the EPA under authority of Section 11003 and 11004 of the Resource Conservation and
    Recovery Act.

    WHO MUST NOTIFY:
    Transporters who transport  regulated medical waste that is generated in a Covered State must notify  the U.S.
    Environmental  Protection Agency for each Covered State's regulated medical waste they intend to transport. This
    requirement extends to transporters who do not actually transport the waste within that Covered State's boundaries but
    who transport the waste, generated in the Covered State, outside that Covered State's boundaries.

    Transporters planning such activity may either complete a Notification Form or submit a letter containing the information
    required in 40 CFR 259.72(b). EPA will then issue a Medical Waste Identification Number unique to that transporter for
    each Covered State for which they are notifying. That number will be used to identify regulated medical waste transporters
    and can be used by generators to verify that the transporter has notified EPA of his intent to transport waste from their
    Covered State.

    WHEN TO NOTIFY:
    Notification must be submitted for a Covered State before the transporter may accept regulated medical waste generated
    in that Covered State. Transporters may, however, accept such waste once they have submitted their notification, but
    before receiving their identification number.  Upon receipt of that number, the transporter must enter it in Box 5 of the
    Medical Waste Tracking Form, when  that form is required.  Additionally, the transporter must enter that number in Box
    17 of the Tracking Form when acting as a secondary transporter, and in Box 1 when initiating a tracking form for load
    consolidation purposes.

    WHERE TO SEND NOTIFICATION:
    Two copies of the completed Notification Form, for each Covered State, must be sent to:
    Chief, Waste Characterization Branch
    Environmental Protection Agency (OS-332)
    401 M Street, S.W.
    Washington, D.C. 20460

    One copy must also be sent to the Director of the  waste management agency in the State for which the transporter is
    notifying.

    NOTIFICATION FORM INSTRUCTIONS:
    Note: All information must be typed or printed clearly.
          Box 1.    Covered State for which you are notifying. Enter the name of the Covered State of origin of the regulated
                   medical waste(s) you intend to collect and/or transport. Enter only one State in this space; if you intend
                   to transport waste from more than one Covered State you must submit a separate Notification Form for
                   each of those States.
          Box 2.    Transporter Name and Mailing Address. Enter your organization's  name, mailing address, the name of
                   a contact person at that location who is knowledgeable about your operations, and include that person's
                   telephone number.
          Box 3.    EPA Hazardous Waste Identification Numbers.  If the facility  identified in Box 2 has an EPA Hazardous
                   Waste  Identification  Number, enter the EPA-assigned 12-character hazardous waste identification
                   number for the facility.
          Box 4.    Transporter's Facility Location(s). Enter the address, facility telephone number, and any current State
                   medical or infectious  waste permit or license numbers for each transportation or transfer facility located
                   within the Covered State identified in Box 1. If there are more than four such facilities in that Covered
                   State you will need to use an additional sheet(s) to provide the required facility information; attach the
                   additional sheets to the first.
          Box 5.    Certification.  The Certification Statement must be read and hand  signed by a corporate officer or the
                   owner/operator of the transporter company.

22

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   United States
   Environmental Protection
   Agency


   Medical WasteTransporter
   Notification Form
     1  Covered State for which you are notifying

    	•	
    2. Transporter Name and Mailing Address


    Name


    Address


    City


    Contact
                  FOR OFFICIAL EPA USE ONLY

                  Identification No.:

                  Date Received:

                  Receiving Official:
                    	•	

                    JPIease Type or Print Clearly)
   State             Zip Code


Area Code/Telephone Number
                                  3. EPA Hazardous Waste ID Number
                                                                        (The ID number entered should be for the facility identified in Box 2)

   4. Transporter's Facility Location(s)           (use additional sheets if necessary)
                                                     Zip Code    i   City
   Area Code/ Telephone Number
                                                                   Area Code/ Telephone Number


                               Address


                  Zip Code    j   City



                               Area Code/ Telephone Number

                        -   I   -
           required to handle
  Area Code/ Telephone Number
                                                                                                (permit or license> «*>"'«* to handle
 Area Code/ Telephone Number
                                                                Area Code/ Telephone Number
                       number(s) (permit or license) required to handle
                                                                                                               'uired to handle
5. Certification
                   Signature
                                                                Title
                                                                                                      Date

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Office of Solid Waste
United States
Environmental Protection
Agency
401 M Street, S.W.
Washington, DC 20460

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