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Part 121 Liquid Industrial By-Products (formerly Liquid Industrial Waste) Statutory Changes


Krista Hettich


On December 17, 2015, an amendment to Michigan's liquid industrial waste statute was signed into law. Two primary changes resulting from the amendment include:

  • Changing the title of the act and references throughout from "Liquid Industrial Waste" to "Liquid Industrial By-Products," and
  • Eliminating the required use of a Uniform Hazardous Waste Manifest to document shipment of liquid industrial by-products to a designated facility authorized to recycle or dispose of the by-products.

The law became effective on March 16, 2016.  Shipping documentation provisions are established under the new law. It allows the use of a Uniform Hazardous Waste Manifest OR another written record which includes: 1) the name and address of the generator, 2) the name of the transporter, 3) the type of by-products shipped, 4) the volume of by-products shipped, 5) the date of shipment from the generator and 6) the name, address and Site ID number of the receiving authorized disposal or recycling designated facility. This change also eliminates the requirement to submit copies of Uniform Hazardous Waste Manifests used for liquid industrial by-products shipments. 



Additional Information

On December 17, 2015, Part 121, Liquid Industrial Waste, of the Michigan Natural Resources and Environmental Protection Act, Act 451 of 1994 as amended was amended by Act 224, establishing “Liquid Industrial By-Products.”  Other statutory changes were made under Acts 225, and 226 of 2015 to provide for conforming laws.  The new laws:

  • Rename Liquid Industrial Waste to Liquid Industrial By-Products,
  • Eliminate the Uniform Hazardous Waste Manifest as the required shipping document for transporting Liquid Industrial By-Products,
  • Define the required elements of a shipping document,
  • Eliminate the requirement to submit copies of the shipping document to the DEQ(now EGLE),
  • Eliminate the requirement to obtain a Site Identification number for liquid industrial by-products generators using a shipping document other than the Uniform Hazardous Waste Manifest,
  • A Site ID Number is not required on the shipping document when the generator:
    • is using a Uniform Manifest as the shipping document for Liquid Industrial By-Products AND
    • the shipment is ONLY Liquid Industrial By-Products (no hazardous waste, for example),
  • Require generators to maintain labeling or marking on containers and tanks to identify the contents,
  • Provide for confirmation of acceptance at the designated facility,
  • Provide the ability to maintain records in an electronic format,
  • Provide for individual authorizations for dually licensed liquid industrial by-products and septage haulers,
  • Provide the ability for transporters to carry registrations and permits in electronic format,
  • Require certain designated facilities maintain a plan to respond to releases,
  • Require certain designated facilities document proper employee training,
  • Require certain designated facilities submit an annual report,
  • Clarify that materials used or reused as an ingredient to make a product are not regulated,
  • Clarify the applicability of closed containers, and
  • Allow for the resolution of violations through civil actions.

For questions pertaining to the Part 121 statutory changes, consider: