_How Mercovi handles EPA, RCRA and DOT requirements: the Uniform manifest, e-Manifest status, 49 CFR 173.12 lab packs, the three storage clocks._ # EPA, RCRA and DOT paperwork, computed from the record. Mercovi is built around the documents EPA, RCRA and DOT require of this trade — the manifest, the material profile, the lab pack rules, the storage clock, the certificate of disposal. Here is exactly what it does with each, in the order they are produced, and what it leaves to you. ### Material profiles (MPDS) The material profile data sheet carries identity, the soil determination with its analytical tests, regulatory status, chemical composition and physical properties. It prints as the document a generator signs and a facility files, and a client's whole profile book downloads as one PDF. _Screen: a material profile data sheet (MPDS) — regulatory status, soil determination, chemical composition and physical properties; prints as the document a generator signs._ ### Lab packs (49 CFR 173.12) Inner container size limits and gross weight are validated at the drum build. Prohibited materials — poison inhalation hazard, 6.1 PG I, temperature-controlled — are flagged with the reason and shipped as their own container. Compatibility cautions are at the category level: category pairs that must not share a drum are flagged. Mercovi does not claim a chemical-level compatibility matrix. > Source: [49 CFR 173.12](https://www.ecfr.gov/current/title-49/subtitle-B/chapter-I/subchapter-C/part-173/subpart-A/section-173.12). _Screen: the drum build — drums by category with outer packaging, absorbent and gross weight, and the manifest lines each category becomes._ ### The Uniform Hazardous Waste Manifest (EPA Form 8700-22) Computed from the waste codes — any RCRA code makes it a Uniform manifest. Continuation sheets when the lines run over. One manifest per designated facility, which is why a job can need more than one. Transporters carry their state registrations with expiry dates. > Source: [EPA — Uniform Hazardous Waste Manifest](https://www.epa.gov/hwgenerators/uniform-hazardous-waste-manifest-instructions-sample-form-and-continuation-sheet). _Screen: a manifest record — parties with EPA IDs, lines with codes and approvals, signatures, and the EPA e-Manifest status on the record._ ### EPA e-Manifest Each manifest carries its EPA e-Manifest status, submission method and tracking number on the record, so the MTN is where the job is — not in an inbox. [How e-Manifest works](/e-manifest) sets out who signs what; a contractor that prepares manifests for its clients is [a broker](/broker). > Source: [EPA — the e-Manifest system](https://www.epa.gov/e-manifest). _Screen: a manifest record — parties with EPA IDs, lines with codes and approvals, signatures, and the EPA e-Manifest status on the record._ ### Accumulation start dates Carried per container from the paperwork, not from the date it arrived at your door. Repackaging does not reset it: a consolidated container takes the earliest parent's start date. _Screen: check-in at the dock — manifested versus received counts, scale weights, locations, and a discrepancy recorded at the dock._ ### The three storage clocks There is no one number of days. Which clock governs a container depends on the facility's status, the generator's status and the state. **The transfer facility exemption** ([40 CFR 263.12](https://www.ecfr.gov/current/title-40/chapter-I/subchapter-I/part-263/subpart-B/section-263.12)). A transporter may hold manifested containers at a transfer facility for a limited period without a storage permit. This is the clock most HHW contractors actually live under when a load comes back to the warehouse. **Generator accumulation** ([40 CFR 262](https://www.ecfr.gov/current/title-40/chapter-I/subchapter-I/part-262)). The limit depends on generator category — LQG, SQG, and distance to the designated facility — and VSQGs are capped by volume rather than time. The regulatory artifact is the accumulation start date on each container, and the clock starts at the first drop, not when the container is full. **Permitted TSDF storage.** The permit sets the limit. There is no single federal number. > Because the governing limit depends on the facility's status, the generator's status and the state, Mercovi stores no day count in code. Each facility carries its own ordered rules and the first rule that matches a container governs it. _Screen: settings — wastes, containers, facilities, methods, qualifications, lab pack categories, floor plans and ordered storage-limit rules, all editable._ ### Certificates of disposal Returned onto the shipment and onto every source generator's record. Where a client's terms require it, the certificate is attached to the bill. _Screen: an outbound shipment — containers aboard, the manifest with the facility as offeror and its e-Manifest status on the record, and the certificate of disposal landed on every source generator's record._ ### Recordkeeping Jobs, manifests, profiles, receipts, shipments, certificates and bills are retained as records, and every document — manifest, profile sheet, dispatch sheet, load order, pack list, receipt sheet, bill, report — is an output of the record rather than something assembled alongside it. Issued bills lock their lines; closed jobs lock their counts. _Screen: a bill — Draft, Issued, Paid; each waste priced from the client's own table on the basis it bills on; PaintCare stated separately; lines locked on issue._ ## Questions about compliance ### Which manifest form does Mercovi use? The form is computed from the waste codes on the lines. Any RCRA code makes it the Uniform Hazardous Waste Manifest, EPA Form 8700-22, with continuation sheets when the lines run over; a shipment with no RCRA code goes on a non-hazardous shipping manifest. There is one manifest per designated facility, so a job with two facilities has two. ### Does Mercovi submit manifests to EPA e-Manifest? Each manifest carries its EPA e-Manifest status, submission method and tracking number on the record, so the MTN is found on the job rather than in an inbox. [How e-Manifest works](/e-manifest) sets out who signs what, and a contractor that prepares its clients' manifests under its own EPA ID is [a broker](/broker). ### How does Mercovi handle the storage time limit? As a status, never as a number of days written into the software. Which limit governs a container depends on the facility's status, the generator's category and the state, so each facility carries its own ordered rules and the first rule that matches a container governs it. The container shows within the limit, near it, or past it. ### What does Mercovi check on a lab pack? At the drum build it validates inner container size limits and gross weight under 49 CFR 173.12, flags prohibited materials — poison inhalation hazard, 6.1 PG I, temperature-controlled — with the reason, and flags category pairs that must not share a drum. It does not claim a chemical-level compatibility matrix; the chemist's judgement stays the chemist's. Questions about any of the above are the best demo we can give you. [Book one](/demo).