Industry Comments on the Form

The following is a summary of key issues raised at the waste tire manifest system client focus group meetings (October 11 and 16, 2001) and public hearings (November 6 and 8, 2001). CalRecycle will consider all issues and welcomes any additional comments and suggestions, which may be submitted to Keith Cambridge. This list will be updated as issues are resolved, decisions made, and as new issues are brought to CalRecycle’s attention.

As SB 876 is implemented, CalRecycle will continue coordinating with and seek assistance from the regulated community and the public.

Key Issues

  1. CalRecycle should provide preaddressed manifest and trip log forms and/or peel-off labels that contain preprinted name and address information.  Even better would be an electronic template that is downloadable from the web.
  2. The Taxpayer ID number should not be used as the unique generator identifier. Many generators are not readily knowledgeable of the number and specifying taxpayer ID information on the forms may provide opportunities for inappropriate use.
  3. Information provided by haulers and generators/end-use facilities must be kept confidential from any use beyond those stated in statue and viewing by ‘downstream businesses’ as would be posted on the trip log.
  4. Who is required to sign the manifest? What if a generator or facility representative is not available to sign the manifest and log?
  5. Is it necessary for the generator to sign the hauler’s trip log? Generators and haulers want to protect business interests and information that may be of interest to ‘downstream businesses’ and competitors.
  6. Generators must be held accountable to manifest. Upon implementation of SB 876, the burden will ultimately fall upon the hauler, including providing manifest forms to the generator and enforcing generator manifest requirements. This will slow down the hauler and potentially prevent ongoing/future business with some generators. Are there or will there be penalties applicable to the generator for not conforming to requirements?
  7. A checkbox should be added to the manifest, on behalf of generators/end-use facilities that complete Part 1 of the form for driver’s without a hauler license (out of state, common carrier/backhaul). Even better would be the use of the driver’s license number.
  8. CalRecycle should provide each hauler and generator, a laminated statement of requirements/law. This will assist the hauler and generator in obtaining the information requested on the manifest and trip log with minimal resistance.
  9. Auto dismantlers are not currently addressed within the Waste Tire Manifest System and should be.
  10. For tire pickups where there is a prepositioned trailer or drop box, waste tire weights can only be estimated based on stated conversion factors.
  11. The manifest should include two decimal places for load measurement in tons.
  12. How can CalRecycle accurately reconcile the number of tires reported where the generator and end-use facility use different waste tire measurement conventions?
  13. How is a vehicle with two roll-off boxes manifested? Are two manifests required?
  14. Can a single hauler who loads and empties a truck several times in a given day use the same hauler trip log?
  15. Forms should require each hauler and generator to print their respective name on the manifest and/or trip log forms. Printed names will assist in identifying signatures that are illegible.
  16. Reconsider Part 3 placement of printed name and signature. Hauler should sign in Part I and generator/end-use representative should print name and sign in Part 2.
  17. It is not clear how the proposed manifest and trip log will handle backhaul, trailer drop/pickup, out-of-state, and international movement of tires with consideration given to registered and unregistered haulers.
  18. Provide accurate waste tire conversion codes for use on the manifest form.
  19. The form should accommodate the specification of size, type, and amount of tires being manifested.
  20. CalRecycle should add tire product codes/descriptions to the manifest form. The generator/hauler would be able to indicate tire type directly on the form. This will help in identifying tires for recycled uses.
  21. The reference to ‘common carrier’ is unclear. The terms ‘common carrier’ and ‘back haul’ need to be defined and differentiated in legislation.
  22. What is the timeframe for submitting the manifest and trip log to CalRecycle?
  23. For Part 2 on the manifest form, does the address and phone information refer to the location of the generator/end-use facility physical plant or billing/accounting office?
  24. How does a hauler manifest and log 3 trailer swaps (i.e. 1-empty drop/1-full pickup, 1-full drop/1-empty pickup, and 1-empty drop/1-full pickup, and 1-final delivery)?
  25. How is a load manifested if a hauler drops a sealed container which is picked up by another hauler (and not opened)?
  26. The manifest form should include check boxes to specify end-use (such as disposal, recycle/retread, fuel). This will assist CalRecycle in tracking the ultimate use of tires.
  27. How will the new manifest requirements apply to haulers from Mexico? Will haulers from Mexico be held accountable to manifest.
  28. Site numbers are used in state ordered clean ups and are important in identifying permitted delivery facilities. Site numbers should be used on the manifest form.
  29. The space for hauler, generator/end-use facility address name and address information should accommodate a business stamp.
  30. A multiple role company (generator, hauler, and end-use facility) must complete too much paperwork with repetitive information. Is there a way to streamline the amount of required paperwork such as adding a checkbox to indicate multiple role organizations?
  31. Any reference to ‘facility’ on the forms should be renamed to ‘end use facility’ to prevent the term from be misunderstood.
  32. On the trip log, the printed ‘business name’ should be indicated in each field where the information is being requested.
  33. Rename ‘decal number’ to ‘vehicle decal number’ on the manifest form.
  34. The CalRecycle ID number should be used in lieu of  ‘Decal #.’
  35. Rename ‘load number’ in the upper right corner of the trip log to log number.’ The reference to ‘log number’ best references a hauler’s daily load activities.
  36. Standardize and consistently apply field-naming conventions throughout the forms and instructions.  Suggest standard form names as follows–manifest or manifest receipt form for the form used by the generator/end-use facilities,–and trip log for the form used by haulers.
  37. The manifest form distribution copies need better identification. The white copy should be identified as ‘CalRecycle copy’ rather than ‘office copy.’  The hauler copy should be the last page for ease of dissemination. All three copies should be on white paper. Color paper does not photocopy well however, haulers are accustomed to retaining the yellow copy. The distribution type (CalRecycle, Generator/End-Use, Hauler) should be printed on the copy to be distributed.
  38. The forms should accommodate haulers who are also the end-use facility, transporting a single pickup and destination load. Many haul types are one-to-one and many haulers are also the generator and/or end-use facility.
  39. How does a private and nonexempt hauler manifest/log several small residential pickups (less than 9 tires each) with a resulting truck load over 10 tires.
  40. Could building and safety inspectors, and fire departments be given the authority to inspect manifests, tire loads, and set amnesty days?
  41. Can reports be generated and made available to generators, haulers and end users from the Waste Tire Manifest System for location and tire type information? This data is useful to the private sector for markets and manufacturing.
  42. CalRecycle should take into consideration the needs of local government with respect to enforcement and remediation of tire abandonment sites. There must be flexibility in the process and the forms should allow local government to addresses such situations with a minimum amount of paperwork (due to time sensitive remediation efforts) and still be within the statute and regulations.
  43. CalRecycle should consider the use of information technology hardware and software that will allow businesses to collect information required in the Waste Tire Manifest System process, electronically using various handheld or wireless hardware. This data can then be uploaded to CalRecycle for processing. Technology should be capable of providing copies and reports of information required by the system. At minimum, CalRecycle should design and develop Internet-based applications that provide businesses with Internet access to enter manifest data on line.

For more information contact: Tire Management Program Hotline,