The transport truck is already at the gate. The drums have been weighed, and everyone is waiting for a signature.
At this point, what matters is not the vendor's permit, but the documents that go up into the truck bed. This document is called a manifest, and its legal basis has changed twice.
Outdated References
The paper manifest originated from the Head of Bapedal's Decree No. Kep-02/BAPEDAL/09/1995 regarding B3 hazardous and toxic waste documents. This regulation was revoked by Permen LHK No. 4 of 2020.
Permen LHK 4/2020 itself is now no longer in effect. It was revoked by Permen LHK No. 6 of 2021, which came into effect on April 1, 2021. In one go, this regulation revoked eleven older regulations, including those regarding the storage and utilization of B3 hazardous and toxic waste issued in 2020.
If your internal procedures still reference the 1995 or 2020 numbers, those references point to regulations that have been revoked.
Festronik and Silacak Are Not the Same
These two names are often used interchangeably. Permen LHK 6/2021 defines them separately.
Festronik, short for Electronic Manifest for B3 Hazardous and Toxic Waste Transport, is an electronic document that contains a handover statement and information about B3 hazardous and toxic waste.
Silacak, the B3 Hazardous and Toxic Waste Transport Tracking System, is an electronic system that stores and displays the transport history. The GPS on the transport vehicle is connected to it.
One answers who handed over what to whom. The other records the path of the waste.
Requirements for the Transporter
PP 22/2021 Article 311 paragraph (1) demands two things at once: a recommendation for B3 hazardous and toxic waste transport and a business permit in the transport sector. One alone is not enough.
Permen LHK 6/2021 Article 97 paragraph (1) adds an obligation that is rarely questioned by producers. The transporter is required to create a Festronik, recap the transport, and report it to the Minister. This report must be copied to the minister in charge of transportation at least once every six months.
The transport vehicles are also differentiated. PP 22/2021 Article 310 requires closed transport vehicles for B3 category 1 waste, and open transport vehicles for category 2.
Proof of Handover Is Your Document
This section is often considered the vendor's responsibility.
PP 22/2021 Article 298 paragraph (2) states that the handover of B3 hazardous and toxic waste must be accompanied by proof of handover. The following paragraph emphasizes that a copy of this proof must be included in the B3 hazardous and toxic waste storage report that you prepare yourself.
So, your responsibility does not leave with the truck. What closes the chain is not the truck exiting the gate, but the copy that returns.
The filling involves three sequential parties: the producer, the transporter, and then the final recipient. The final recipient can be a collector, user, processor, or storer. If the signature of the third party never comes in, the chain hangs in your hands.
Regarding how long waste can wait before being handed over, the calculation is discussed separately in the article on the time limits for storing B3 hazardous and toxic waste.
What to Check This Week
Try opening one of your latest manifest documents and check four things.
First, the regulation number listed in the procedure, does it still mention 1995 or 2020? Second, is there really a copy of the handover proof from the final recipient, not just proof of departure? Third, does your transporter hold both the recommendation and the business permit, not just one of them? Fourth, has that copy been included in your storage report?
A tidy archive does not close the manifest chain. What closes it is the last signature.
Sources
- PP No. 22 Tahun 2021 tentang Penyelenggaraan Perlindungan dan Pengelolaan Lingkungan Hidup, JDIH BPK RI
- Permen LHK No. 6 Tahun 2021 tentang Tata Cara dan Persyaratan Pengelolaan Limbah B3, status Berlaku, JDIH BPK RI
- Permen LHK No. 4 Tahun 2020 tentang Pengangkutan Limbah B3, status Tidak Berlaku, JDIH BPK RI
- Mekanisme Pengelolaan Limbah Bahan Berbahaya dan Beracun Berdasarkan Peraturan Perundang-undangan, Tulisan Hukum JDIH BPK Perwakilan Provinsi Banten, 2025