Are You Correctly Using the Hazardous Waste Manifest at Each Waste Pickup?

Man-Filling-Out-Hazardous-Waste-Manifest-FormThe Environmental Protection Agency’s hazardous waste manifest system was created to track hazardous waste from the time it leaves the facility where it was generated, until it reaches the off-site facility for storage, treatment, or disposal. The Uniform Hazardous Waste Manifest is the form that is the key component of the system, and it helps ensure accountability in the transportation and disposal process.

The manifest has information on the type and quantity of the waste that will be transported and instructions for handling it. Each party who handles the waste must sign the manifest and keep a copy for themselves. After the waste has reached its final destination, the receiving facility confirms that it has been received and properly handled by returning a signed copy of the manifest to the generator. Only then can the generator be assured that the waste was properly disposed.

Let’s look at a few common questions about the manifest system to help ensure that you use it correctly.

What is Hazardous Waste Manifest

A Hazardous Waste Manifest is a critical tracking document used in the transportation and disposal of hazardous waste. This legal document accompanies hazardous waste from the point of generation to the final disposal facility, ensuring that all hazardous materials are properly handled, tracked, and disposed of according to regulatory standards. The manifest contains detailed information about the waste, including its quantity, composition, and the names and addresses of the waste generator, transporter(s), and disposal facility. It serves multiple purposes: it provides a paper trail for waste shipments, ensures regulatory compliance, and enhances the safety of workers, the public, and the environment by ensuring that hazardous waste is not improperly disposed of.

Hazardous Waste Manifest

Under regulations such as the Resource Conservation and Recovery Act (RCRA) in the United States, the use of a hazardous waste manifest is mandatory for most types of hazardous waste, and each party involved in the handling of the waste must retain a copy of the manifest for a specified period, facilitating accountability and traceability throughout the waste’s lifecycle.

What Information Must be Included on a Hazardous Waste Manifest?

A Hazardous Waste Manifest must include comprehensive information ensuring safe and regulatory-compliant handling, transportation, and disposal of hazardous waste. The required information typically encompasses:

  1. Generator Information: This includes the name, address, and EPA identification number of the entity generating the hazardous waste. It also may require contact information for a responsible individual at the generating facility.

  2. Transporter Information: The names and EPA identification numbers of all transporters involved in shipping the hazardous waste. Transport companies must be registered and approved for handling such materials.

  3. Designated Facility: The name, address, and EPA identification number of the facility where the waste will be treated, stored, or disposed of. This ensures that the waste is going to a facility capable of handling it legally.

  4. Manifest Tracking Number: A unique number assigned to each manifest that helps track the waste from origin to disposal.

  5. Description of the Hazardous Waste: Detailed information including the number of containers, type of containers, the total quantity of waste, and the specific hazardous waste codes as defined by regulatory agencies. This section must accurately describe the waste to inform handlers and disposal facilities of the potential risks.

  6. Hazard Classifications: Information on the hazards associated with the waste, such as toxicity, flammability, corrosivity, or reactivity. This is crucial for ensuring safe handling and transportation practices.

  7. Emergency Response Information: Detailed instructions in case of an accident or spill, including emergency contact numbers. This section is vital for an immediate and appropriate response to protect health and the environment in case of an incident.

  8. Signatures: Representatives from the generating facility, each transporter, and the receiving facility must sign and date the manifest. These signatures certify that the information is accurate and that the waste has been properly handled and received in accordance with regulations.

Are There State Requirements for Manifests?

Some states have additional requirements such as state-specific waste codes for the hazardous waste manifest. EPA provides a list of hazardous waste manifest programs in state environmental agencies to help you follow the regulations in your state. (A contact name and phone number is provided for states that have not completed a manifest web page.)

Also, as a hazardous waste generator, it is your responsibility to determine whether your state or the consignment state for a shipment, if your waste will travel out of state, regulates any additional wastes as hazardous wastes beyond those regulated federally. If so, they would be regulated under the consignment state’s authorized program.

Important to note: You must also determine whether the consignment state or generator state requires you to submit any copies of the manifest.

Who Can Print the Manifests?

Did you realize that the source printing the manifests has to receive approval from the Environmental Protection Agency (EPA)? EPA Manifest Registry approves printing and distribution of the forms, and you may apply to print the manifests as a hazardous waste generator. Other registered sources may include a state agency, a commercial printer, your hazardous waste transporter or treatment , storage, disposal facility (TSDF) as well as any other preparer such as a hazardous waste broker who either prepares or arranges shipments of hazardous waste for transportation.

Important to note: Make sure that your approved registrant has included your manifest tracking number (MTN) in Item 4 of your manifest form.

How Many Copies Do You Need?

Once the information is correctly filled out on the manifest, you must determine how many copies you will need to provide. You will at least need copies for the following:

  • The Department (if required)
  • The generator
  • Each transporter
  • The owner or operator of the designated facility

Important to note: You will need one copy each for their records and another copy that is returned to you, the generator.

How Do You Certify the Manifest?

As the hazardous waste generator, you or your designed manifest signer must sign the manifest certification by hand. Stamps are not allowed. You must also obtain a handwritten signature from the initial transporter and include the date that the waste was accepted. One copy is retained for your records and the transporter receives the remaining copies of the manifest.

Important to note: You are also required to provide a waste minimization certification, as outlined on the uniform hazardous waste manifest. Basically, if you are a small quantity generator (SQG) you must attest to having made a good faith effort to minimize your waste generation and use the best waste management method available. Large quantity generators (LQGs) must have an actual program in place to reduce the volume and toxicity of the hazardous waste they generate.

How Long Must Hazardous Waste Manifests Be Kept

You are required to keep a copy of each manifest that you or your representative signs for three years or until you receive a signed copy from the designated facility that received your waste. That signed copy must be kept as a record for at least three years from the date that your waste was accepted by the initial transporter. (Some facilities keep copies as long as they are in business, as a best practice.)

Important to note: If, as a small quantity generator, you do not receive a signed copy from the designated TSDF within 60 days of shipment, you must submit a legible copy of the manifest to your state or EPA regional office. This indicates a signed copy was not received from the facility operator.

What About Electronic Hazardous Waste Manifests?

EPA launched the e-Manifest system on June 30, 2018 to electronically track hazardous waste shipments. The goal is to transition to an electronic system for cost savings and increased efficiencies. An electronic manifest may be used to track hazardous waste shipments only if you know at the time the manifest is originated that all of the waste handlers who are named on the manifest participate in the electronic manifest system.

Important to note: Generators who originate an electronic manifest must also provide one printed copy of it to the initial transporter. EPA recently granted extra time for receiving facilities to submit paper manifests during the initial months after the system launch and additional functionality will deploy throughout the fall of 2018.

The Uniform Hazardous Waste Manifest is designed to track your hazardous waste from the time it leaves your facility, until it reaches the off-site waste management facility that will store, treat, or dispose of it. Proper use of the form is key to managing the transportation and disposal of hazardous waste. Your waste management provider should be able to answer any questions you have about the manifest system.

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