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Electronic Waste Manifest Documents

What does the law say about the validity of the Waste Manifest documents that are issued electronically? 

A Waste Manifest document is a legal requirement prescribed by the Waste Classification and Management Regulations, 2013 under the National Environmental Management: Waste Act 59 of 2008 (NEMWA). Regulation 11 of the Waste Classification and Management Regulations, 2013 requires that:

  1. Every holder of hazardous waste must be in possession of a Waste Manifest document containing the relevant information specified in Annexure 22 of the Regulations.
  2. Generators of hazardous waste must complete a Waste Manifest document containing the information specified in Annexure 2 for each consignment of waste transported to a waste manager.
  3. Waste transporters must not accept hazardous waste for transport, unless the Waste Manifest document accompanies the waste.
  4. All transporters of hazardous waste must:
  • complete a Waste Manifest document containing the information specified in Annexure 2 of the Regulations for each consignment of waste transported;
  • provide the information to the generator before the waste is transported from the premises of the generator; and
  • provide the information to the waste manager at the time of delivery of the waste to the facility for a waste management activity.
  1. Waste managers must not accept hazardous waste unless the Waste Manifest document accompanies the waste.
  2. All managers of hazardous waste must complete the Waste Manifest document with the information specified in Annexure 2 confirming that the waste load has been accepted and that the waste has been managed.
  3. All waste generators, transporters and managers must:
  • retain copies, or be able to access copies / records, of the Waste Manifest documentation for a period of at least five years; and
  • make the Waste Manifest documentation available to the Department of Health upon request. 

In all of these obligations pertaining to the Waste Manifest system and documentation, there is no requirement for the original Waste Manifest document to be provided to, or be in the possession of, the generator of the hazardous waste.

It is also permissible for waste generators, transporters and managers to retain copies (not originals), or alternatively be able to access copies or records of the Waste Manifest

documentation electronically and again, not necessarily the original documents. 

To find out more about Compass and our compliance measures, please visit http://www.compasswasteservices.co.za or email customercom@compass.za.ne

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