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The Hazardous Waste Manifest System is a set of forms, reports, and procedures designed to seamlessly track hazardous waste from the time it leaves the generator facility where it was produced, until it reaches the off-site waste management facility that will store, treat, or dispose of the hazardous waste. The system allows the waste generator to verify that its waste has been properly delivered, and that no waste has been lost or unaccounted for in the process.
The key component of this system is the Uniform Hazardous Waste Manifest which is a form prepared by all generators who transport, or offer for transport, hazardous waste for off-site treatment, recycling, storage, or disposal. Currently, the manifest is a paper document containing multiple copies of a single form. When completed, it contains information on the type and quantity of the waste being transported, instructions for handling the waste, and signature lines for all parties involved in the disposal process. The manifest is required by both Department of Transportation and EPA. Each party that handles the waste signs the manifest and retains a copy for themselves. This ensures critical accountability in the transportation and disposal processes. Once the waste reaches its destination, the receiving facility returns a signed copy of the manifest to the generator, confirming that the waste has been received by the designated facility.
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Specifically, the current paper system works as follows:
Many States also require the TSDF to send the State a copy of the manifest signed by the TSDF. Approximately 26 States require manifest copies from generators, TSDFs, or both. The requirement to submit copies to States is not based on Federal requirements, but on the needs of State programs that use manifest data for purposes of compliance monitoring, capacity planning, and program management.
If a generator does not receive a copy of the manifest signed by the designated facility owner or operator within 45 days of the date that the waste was accepted by the initial transporter (60 days for small quantity generators), the generator must file an exception report (Section 262.42). Conditionally exempt small quantity generators (CESQG's) are not required by federal regulations to use a manifest when shipping their waste off-site. CESQG's are defined under Section 261.5 as generators that produce, monthly, 100 kg or less of hazardous waste; 1 kg or less of acutely hazardous waste; or 100 kg or less of contaminated soil, waste, or debris resulting from clean-up of an acute hazardous waste spill.
NOTE: The regulations outlined above only apply to domestic shipments of hazardous waste by road. Domestic shipments made by rail or water are subject to streamlined manifesting requirements, and hazardous waste shipments exported from the US are subject to additional requirements. The information on this website pertains to federal regulations only. Contact your authorized State program for the RCRA regulations that apply in your State. Please also note that the description above is only a summary of the regulations and should not be used as a substitute for the regulations themselves. To review the full text of these regulations, click on 40 CFR Part 261 or 40 CFR Part 262 .
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Who is responsible for the Hazardous Waste Manifest?
The current Hazardous Waste Manifest is a joint undertaking by EPA and the Department of Transportation (DOT). EPA is responsible for regulating hazardous waste under a Federal statute known as the Resource Conservation and Recovery Act (RCRA). This Act requires that all hazardous waste shipped off-site be tracked from "cradle-to-grave" using a manifest that provides information about the generator of the waste, the facility that will receive the waste, a description and quantity of the waste (including the number and type of containers), and how the waste will be routed to the receiving facility. Because hazardous waste is also regulated by the DOT under its hazardous materials laws, the Manifest was developed to meet both EPA's requirements for a manifest, and DOT's requirements for "shipping papers
Does EPA currently collect manifests?
No. The Federal regulations do not require the routine submission of manifests to EPA, except when there are problems with a shipment which the generator and receiving facility cannot reconcile. Moreover, the hazardous waste regulatory program has been largely delegated to the state level, so most day-to-day implementation and inspection activities are carried out by "authorized states", rather than by EPA. However, about 30 States do routinely collect manifests, and these State programs now enter the data contained in these paper manifests into their databases for tracking purposes. The data is used by the states for estimation of hazardous waste management capacity, compliance targeting and enforcement, program management, and to generation of revenue.