What Is A Hazardous Waste Manifest & What Do You Do With It?

A hazardous waste manifest is a document used to track hazardous and non-hazardous waste shipments nationwide. 

Up until June 30, 2021, manifests could come in paper form. However, the U.S. Environmental Protection Agency revamped tracking of hazardous waste shipments by creating an electronic manifest system (e-manifest), modernizing how the agency follows thousands of shipments every day. Now, all receiving facilities must submit paper manifests either via image upload or data plus image upload to EPA's e-Manifest system.

A hazardous waste manifest tracks a shipment front the point of generation through transportation and to the final treatment storage and disposal facility (TSDF).

As a hazardous waste generator, you need to follow all federal regulations associated with your hazardous waste disposal. This includes submitting a hazardous waste manifest form that ensures your waste is identified correctly and handled appropriately within the law.

Who Must Register In The E-Manifest System

According to the U.S. Environmental Protection Agency, the following businesses must register in the e-manifest system: 

• Hazardous waste generators
• Hazardous waste transporters 
• Receiving facilities 
• Brokers for hazardous waste generator clients
• State inspectors to monitor activity in their state

Registration is important because an entity must be registered to view manifest records in the system or to submit any data corrections to manifests. 

All manifest data is publicly available 90 days after the e-manifest system receives it, so the public does not need to register to see manifest information.

What Is Required For Registration

To register for the e-manifest system, companies must obtain an EPA ID number. Companies can apply for this identification number electronically. The Resource Conservation and Recovery Act also allows companies to register with their state environmental agency if that service is available.

Once your company has an EPA ID number, you must assign a site manager that will manage and approve permissions for other users of the e-manifest in your organization. This is an important position within your company since site managers can see billing invoices and submit payments for your site.

Once you have these two key pieces of information, you can begin the registration process on the RCRAInfo site. The EPA will then approve your registration.

How The Manifest System Works

When a generator logs onto the e-manifest system, the first step is to initiate a new manifest and enter any information about the hazardous waste shipped.

After the generator schedules the shipment with the destination facility, a hazardous waste transporter will pick up the waste. Every step of the way, the uniform hazardous waste manifest is updated electronically. When the initial transporter picks up the waste, the transporter logs into the e-manifest system and signs the manifest. The generator must then sign the manifest. 

Once the hazardous waste reaches its destination, a representative at the TSDF logs into the manifest system and signs for the waste. 

Benefits To Companies Filing Manifests

While the EPA charges user fees to receiving facilities, these fees may trickle down to companies generating hazardous waste. Lower costs can benefit everyone.

Generators also benefit from this electronic system because it can save valuable time on paperwork while providing accurate and timely information on your waste shipments. A central hazardous waste manifest system also provides a single source of information for data should you need to access that information down the road.

A hazardous waste manifest also protects you as a generator, allowing you to have proof that your waste reached its final destination. That’s important since you are responsible for the waste you generate even through its disposal. 

These cradle to grave requirements help to ensure companies stay in compliance and are operating by the book. Quickly becoming aware of discrepancies or problems related to your shipment will help to ensure everything is in order with the disposal of your waste, saving you headaches that in the end can be costly due to fines.

Other E-Manifest FAQ’s

Here are some frequently asked questions about e-manifests, including who must submit a manifest and whether you can still use paper manifests.

Who Must Submit A Manifest To The EPA?

Federal and state laws generally determine which wastes must be shipped under a manifest. If the waste you generate does not fall under federal and state regulations as being hazardous, you likely do not need to submit a manifest.

However, it is extremely important to know each state’s laws that your waste is traveling through on its route. That’s because while your state may not consider your waste as hazardous, the state along the route to disposal may consider the waste hazardous. In this case, submitting a manifest is required. Keep in mind that your receiving facility may require manifests as well.

Do I Need A Manifest Even If I Don’t Generate A Lot Of Waste?

Under the Generator Improvements Rule, The EPA allows Very Small Quantity Generators (VSQGs) to ship their waste to a Large Quantity Generator (LQG) for consolidation IF the same person or entity controls BOTH. If this occurs, regulations do not require a manifest from the VSQG to the LQG as long as containers are properly marked.

Can I Still Use Paper Manifests?

It depends. The EPA no longer accepts paper manifests mailed in for processing. However, receiving facilities can submit paper manifests either via image upload or data plus image upload to the e-manifest system. 

This will cost you more, however. For the 2022 and 2023 fiscal years (Oct. 1, 2021, through Sept. 30, 2023), a fully electronic manifest is just $8, according to the EPA’s fee schedule, which is outlined below. 

Can I Use Old Manifest Forms?

The EPA has required the use of a new 5-copy manifest form since the e-manifest system became available in 2018. This 5-copy form removes and consolidates two of the old 6-copy forms that many companies used prior to 2018. 

The 5-copy form replaces the two copies that were previously earmarked for distribution to states with one copy that is submitted to the e-manifest system, according to the EPA.

The approved registered printers for EPA’s manifest registry page on the EPA site shares the organizations where you can obtain a blank manifest form.

How Do The New Manifest Forms Differ From The Old?

In addition to a new 5-copy form (rather than 6-copy form), there are a few new changes to the updated manifest forms. According to the EPA:

• The copy distribution notation at the bottom of page 1 requires the receiving facility to submit the copy to the e-manifest system.
• There is a warning notice to receiving facilities at the bottom of page 3. This notice advises all facilities that if they receive waste that is accompanied by a manifest, they have responsibilities under the e-Manifest Act (described in the form’s instructions).
• Each copy of the manifest has its own set of instructions that corresponds to the handler type. The new form includes instructions for receiving facilities as well.

Does E-Manifest Apply To Shipping By Rail?

Rail company can designate a company official to register with e-Manifest. This person will sign manifests received at the rail company electronically. 

If the manifest is a paper copy, the rail company must sign the manifest at the rail company office. The manifest copy then goes to the next non-rail transporter or receiving facility.

Are Consolidated Waste Manifests Subject To E-Manifest Requirements?

A common question is whether “milk-run” or “consolidated waste” manifests must be submitted to the federal e-Manifest database. The answer is: no. Because these are separate tracking documents that are only required by certain states, companies should submit these types of manifests to appropriate state agencies only.

Is Household Hazardous Waste Subject To E-Manifest Requirements?

No, household hazardous wastes (HHWs) are generally exempt from the RCRA manifest as long as all regulatory conditions for an HHW exemption are met. 

However, it’s important to note that some states require manifests for some HHW shipments. For example, a state may require a manifest for a shipment of HHW that has been gathered through a collection program. 

Use A Reputable Hazardous Waste Transporter

Because hazardous waste transportation laws can vary, it’s critical to check both your state’s regulations and federal laws to ensure you are meeting all manifest requirements. A good licensed and bonded hazardous waste transportation company can do all this for you. 

The EPA provides additional frequently asked questions about e-manifests on its website to help ensure you have the information you need to safely transport your waste and meet all regulations.