Is Dispo a waste broker under TCEQ rules?

What Texas actually regulates

Texas Commission on Environmental Quality (TCEQ) regulates generators (who produce the waste), transporters (who haul it), and TSDFs (treatment, storage, and disposal facilities). Each role has registrations, manifest obligations, and inspection exposure.

Texas does recognize the concept of a “waste broker” — someone who arranges for the transportation and disposal of waste on behalf of the generator, often as an intermediary. Brokers have their own registration expectations in some cases, and they bear some responsibility in the chain.

Why Dispo isn't acting as a broker

A broker stands in the transaction. They accept the job from the generator, contract with a hauler, and the generator's paperwork flows through them. If the waste ends up misrouted or mishandled, the broker has regulatory exposure.

Dispo doesn't stand in the transaction. The transaction is directly between the generator and the licensed hauler. Specifically:

• We don't take title. The waste never becomes Dispo's. It's the generator's until pickup; it's the hauler's and TSDF's after.
• We don't sign manifests. The EPA Form 8700-22 (Uniform Hazardous Waste Manifest) is between the generator and the hauler, with the TSDF closing the loop. Dispo is not on it.
• We don't arrange disposal. Either the generator specifies the TSDF (common) or the hauler sources one (also common) and names it on the bid. Dispo doesn't negotiate disposal capacity.
• We don't hold ourselves out as “Dispo will take care of your waste.” The marketing is clear: we're a marketplace for generators to find licensed haulers.

The closest analogy: Thumbtack for industrial waste. Thumbtack isn't a contractor; it's software that lets homeowners find contractors. TCEQ doesn't regulate Thumbtack. Same logic.

What does this mean for generators using Dispo?

Your regulatory posture is unchanged. Your EPA ID still appears on the manifest. Your biennial hazardous waste report still draws from your manifests. Dispo doesn't introduce a new regulatory entity into your chain.

What does change: you have better documentation. The Dispo Terms Record is a time-stamped, both-parties-signed artifact of what was agreed at the moment of acceptance. That's the thing that dispute mediators, auditors, and internal accounts payable actually want.

What does this mean for haulers using Dispo?

Same deal. You're still the licensed transporter. Your EPA ID, TCEQ registration, ISN/Avetta status, USCG certifications, and insurance are all yours and displayed on Dispo as provided by you. The Terms Record names you as the contracted party to the generator.

Dispo doesn't charge the generator for your work. Dispo doesn't collect escrow. Dispo doesn't intermediate payment. You bill the generator; the generator pays you. The subscription fee you pay Dispo is unrelated to any specific job's revenue.

What we're doing anyway

Even though we're confident Dispo isn't a broker, “confident” isn't “enforced by a Texas attorney.” Before we take the pilot public, we're:

• Engaging a Texas environmental-law attorney to review our Terms of Service, Privacy Policy, and marketplace positioning.
• Adding explicit disclaimers in-app: each accepted-bid moment will show “Dispo is not the manifest of record; your EPA ID and operational process are unchanged.”
• Calling TCEQ's industry-assistance line, explaining the model, and documenting what we heard.
• Holding E&O insurance covering software-provider liability.

Disclaimer: this post reflects our reading as of 2026-04-23 and is not legal advice. If you're the person who signs filings for a generator or hauler, consult your own Texas-licensed environmental attorney.