Selecting competent and reliable hazardous waste transporters and management facilities is extremely important. As a generator, you have "cradle-to-grave" responsibility for the hazardous waste you produce. No amount of contract language can insulate a generator from potential liability if their hazardous wastes eventually cause a problem. Therefore, in order to minimize the potential for future expense, it is in your best interest to choose services which are legally authorized, have high safety standards, and show a good track record. Although cost is certainly a major factor, quality of service should be your primary concern.

Before selecting a transporter or treatment, storage, or disposal facility (TSDF), obtain information about their services. Be sure they meet your needs, particularly in the area of environmental compliance assistance and wastestream capabilities. Then do a little background check into their regulatory status, safety record, and customer satisfaction.

These criteria and others are outlined in more detail below to provide some guidance for comparing alternative services. (Note: TSDFs that are also transporters, and transporters that also operate a storage facility, should be evaluated for both criteria.)

| Hazardous Waste Transporters | Waste Management Facilities |

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Hazardous Waste Transporters

Required Permits, etc.

Hazardous waste transporters should have:

1. An EPA/state identification number;
2. Hazardous waste transporter registration with the State Department of Toxic Substance Control (DTSC) (ask for a copy or call DTSC at (916) 324-2430 to verify current registration);
3. Hazardous materials transporter registration with the U.S. Department of Transportation (DOT);
4. A hazardous materials/waste endorsement from the Department of Motor Vehicles (DMV);
5. Registration in the destination state for interstate transport (if applicable).

Safety, Training, & Equipment

You will want to make sure that the facilities or transporters you choose operate under strict safety and training standards to minimize the potential for accidents or spills involving your waste. Look for services which offer financial indemnification for any costs related to the negligence or misconduct on the part of the service provider, its employees, or contractors.

Both transporters and TSDFs should have training programs which address:

1. Facility evacuation
2. Use and inspection of safety and emergency equipment
3. Emergency response procedures and contingency plan follow-through
4. Container labelling and vehicle placarding
5. Regular facility/vehicle maintenance checks

Contingency plans should designate equipment and trained personnel for emergency/spill response.

Transporters should also have a list of private emergency response contractors which can respond along established transportation routes.

See Waste Management Facilities: Safety, Training, & Equipment Section for hazardous/waste handler requirements.

Hazardous waste transporter drivers must also be trained in pre-trip safety inspection; vehicle controls, equipment, operation, and handling; compatibility and segregation of cargo in mixed loads; package handling methods; and load securement. Also, check to see if the company has a thorough drug screening policy for its drivers.

Training records or copies of employee training certificates can verify fulfillment of training requirements. Training record information is also available in inspection reports (see below).

Liability Insurance

To minimize your liability, be sure the services you select meet or exceed minimum liability requirements (a copy of the Certificate of Insurance will show the amount of insurance coverage held by the company).

Transporters must meet minimum liability requirements for the type and quantity of hazardous waste being transported in order to register with DTSC. A current hazardous waste transporter registration indicates the transporter has met DTSC's insurance requirements. If you need more specific information about liability requirements for transporters, call DTSC at (916) 324-2430.

Inspection Records

Many of the criteria described above can be checked using available inspection reports:

Hazardous waste transporters are inspected annually by the California Highway Patrol (CHP) The following elements are evaluated:

1. Vehicle maintenance program and records
2. Driving records (including "point counts") and drivers license information
3. Hazardous materials transportation procedures to ensure compliance with DTSC, CHP, and DOT requirements
4. Carrier ID requirements
5. Mechanical condition of vehicles

A report describing the findings and transporter's rating of satisfactory or unsatisfactory can be ob- tained through the MISTER program.

The Management Information System of Terminal Evaluation Records (MISTER) maintains two types of records available through the CHP Commercial Records Unit. Ask for the complete MISTER, which includes safety ratings, basic information such as emergency contacts, a list of all hazardous waste/ materials accidents and spills, and a list of all tickets issued or violations incurred.

To order, call the CHP at (916) 322-7157 for request forms. There is a service charge and you will need to provide the transporter's California carrier num- ber issued by the CHP ("CHP" number).

References

Transporters and TSDFs should be able to provide you with a list of customers in your geographic area who generate a similar wastestream(s). Call some and ask about the length of service, satisfaction with service, company reliability, safety practices, whether there have been any spills, emergency incidents, or other mishaps, and any other information pertinent to your circumstances.

Disposal Options

Know where your waste is going, how:it is being managed, and the final disposition of any residues, ash, or empty containers. Ask how "off-spec" waste shipments will be handled.

Some transporters have direct relationships with various TSDFs and assist in making arrangements for waste disposal. Others act only as "haulers," which requires that the generator make arrangements with the destination facility. In either case, get information or-your waste management facility options (see right).

Compliance Assistance

It is important that your service provider keep up-to-date withhazardous waste transportation/disposal requirements and regulations. Larger firms may have full-time environmental staff, but even small companies can subscribe to publications, attend workshops, or contract for part-time consulting services. Ask companies how they keep abreast of new requirements and choose one which is informed.

Some companies provide customers with private consultations, classes on proper labelling and manifesting, and/or newsletters highlighting new developments and regulations. Look for companies that will assist you in sampling, profiling, manifest preparation, and waste sample shipment, as well as provide you with the 24-hour emergency phone number required for your hazardous waste shipments.

Cost

Ask the sales staff about minimum charges and options for reducing costs which may not be obvious (e.g. pick-up as needed vs. regularly scheduled pick-up).

Look for transporters offering "milk run" services, which allow you to share some of the transportation costs with other small quantity generators transporting drums on the same load. Be sure to find out all costs irt advance - many companies separate the various fees involved (e.g. fee for number of drums, fee for truck use, fee for driver time, fee for distance traveled, etc.)

Site Visit

If possible, make a site visit before contracting for services. Look for:

• A clean and orderly site and well-maintained equipment/vehicles
• Clear hazard signs and safety warnings
• Properly contained and organized hazardous waste storage areas (no large backlog or stockpiling of empty containers, etc.)
• Adequate supervision of operations
• Appropriate employee safety precautions
• Easy access to safety and emergency response equipment and MSDSs
• Control points and spill containment possibilities
• Adequate security provisions (e.g. fences, locks, alarms, warning signs, etc.)
• Organized record keeping system (how do they track manifests, how often do they inspect the facility, etc.)

Most transporters working with specific TSDFs audit them periodically to ensure xninimum standards are met. If you cannot visit the site yourself, you can use one of these transporter services, a consulting service which evaluates TSDFs, customer referrals, and/or inspection reports.

Additional Information

For hazardous materials transportation regulatory requirements, call the CHP's Hazardous Materials Section at (916) 327-3310.

For additional hazardous waste transportation regulatory requirements or a list of registered transporters in the State, contact the DTSC Trans- portation Unit at (916)324-2430 or the DTSC Re- gion 2 office at (510)540-3508.