From the archives of the Enforcement and Compliance Listserv for Hazardous Waste Generators

March 2010

In Missouri:

Volatile wastes that have a true vapor pressure of greater than 78 millimeters (mm) of mercury at 25 degrees Celsius shall not be placed in an open tank. This regulation is meant to prevent hazardous wastes from volatilizing into the air.  If volatile hazardous wastes with a true vapor pressure higher than 78 mm are stored in an open tank, this would be considered a violation of this regulation and could be considered illegal treatment of a hazardous waste and a violation of proper tank conditions. Other things to consider include the very real potential for vapors that volatilize off of the hazardous waste to ignite or injure workers. See 10 Code of State Regulations (CSR) 25-5.262(2)(C)2.F(I) for more information.

Large and small quantity hazardous waste generators must have all completed hazardous waste manifests returned to them within 35 days of initial transport. This is to ensure that your hazardous waste is being properly and timely transported to its destination facility.  If your business does not receive the completed manifest within 35 days of the initial pickup, you must complete and submit a Hazardous Waste Generator's Exception Report 780-0651 within 45 days of the initial transport. Exception reports must be kept for three years. It is a good idea to log all hazardous waste shipments so that you can track when you receive your completed hazardous waste manifests. Your log can include information such as the initial date transported, Uniform Hazardous Waste Manifest tracking number, completed manifest received date, waste type, and quantity. This information can not only help you keep track of your hazardous waste, it can also aide in evaluating your hazardous waste service providers' invoices such as those from transporters, consultants, and treatment, storage, and disposal facilities. See 10 CSR 25-5.262(2)(B)5 and 10 CSR 25-5.262(2)(D)2 for more information.

In addition to exception reporting, large and small quantity generators must retain registration information and the Generator's Hazardous Waste Summary Reports for at least three years. This information includes your Notification of Regulated Waste Activity form and quarterly or annual reports. The three year period begins from the initial day of hazardous waste transportation. The Missouri Department of Natural Resources (DNR) may request in writing that you retain records longer.  The period of record retention is automatically extended during the course of any unresolved enforcement action regarding the regulated activity.  See 10 CSR 25-5.262(2)(D) for more information. 

If you import hazardous waste you must register with the DNR as a generator. You must also specifically identify hazardous wastes intended to be imported four weeks in advance of doing so. As an importer you must keep and maintain the following information: individual original foreign generator's names and addresses for all mixed bulk shipments, the hazardous wastes' technical chemical name from each source, the quantity of waste imported from each source, and the list of EPA waste numbers (i.e waste codes). Exporters of hazardous waste must also send copies of exception reports and annual reports to the DNR. See 10 CSR 25-5.262(2)(F) for more information.

Nov. 30, 2008

Have you organized your manifests lately?

Small and large quantity generators must keep all uniform hazardous waste manifests for three years. Generators that are under enforcement must keep their manifests even longer according to 40 CFR 262.40(d). It is a good idea to have a centralized location for your manifests and file them chronologically. You may also want to develop a log sheet for your manifests that shows the manifest number, date transported, volume of waste, and the date that you receive the manifest back from the receiving facility. Manifests must be returned to the generator within 35 days of transport. A log sheet like this will track your outstanding shipments of hazardous waste and make sure that every manifest you send is returned to your company. If you do not receive your hazardous waste manifest within 35 days from the receiving facility, your company must fill out a Generator's Exception Report within 45 days of the initial shipment. This report is available online.

Aug. 29, 2007

Container Weight on the Manifest.

To correctly fill out the Uniform Hazardous Waste Manifest, the weight of the entire container, waste, packaging, etc. must be recorded on the manifest. The weight including container is also used to determine if the hazardous waste equals or exceeds the reportable quantity. For more information on the Uniform Hazardous Waste Manifest, visit

November 3, 2006

Cracking the code on the new Federal Uniform Hazardous Waste Manifest

After a look at the new manifest you may be wondering where to start when it comes to codes. What codes do I record? Where? How many? How does this affect the hazardous waste management process? The new federal uniform hazardous waste manifest implemented on Sept. 5, 2006, requires two types of codes:

Waste Codes - Waste codes should look familiar to most of you since they are exactly the same as before the September 5, 2006, change. In fact, state specific Waste Codes, for which there are no federal equivalents, are the only state information required on the new manifest at this time. These are M001 through M012 for PCB wastes, MH02 for dioxin waste, D096 for the disposal of used oil with less than 50 ppm PCB's and D098 for the disposal of used oil. Please refer to Missouri Hazardous Waste Regulations 10 CSR 25 Chapters 4, 11, and 13 for detailed descriptions of each waste code. Waste Codes can be found in item thirteen on the new manifest. The obvious difference is that the uniform manifest accommodates six waste codes for each waste, whereas the old Missouri manifest allowed for only two. This does not mean that there will always be multiple descriptions for each waste. The extra space simply allow for a more detailed description of wastes that may be characterized by more than one or two waste codes. The Code of State Regulations will eventually be modified to incorporate the federal regulations concerning the new manifest. Visit Missouri's proposed manifest rule for more information.

Management Method Codes - Management method codes are filled out by a representative of the designated treatment facility. These codes are found in item nineteen of the uniform manifest and describe the types of treatment, disposal, and/or recycling the waste has undergone at the designated facility. These codes provide a specific description of what is happening to your waste. Only one code that best describes the way each waste is managed should be designated. After you receive the copy of your manifest back from the treatment facility, you can figure out what specifically happened to your waste. For example, if the treatment facility used the management method code H020, that means your waste solvent was distilled for solvent recovery. See the U.S. Environmental Protection Agency's (EPA) List of Management Method Codes for the entire listing.  The Management Method Code has also replaced the Final Handling Code on the Generator’s Hazardous Waste Summary Report.

The bottom line is the codes are here to help. By clearly understanding the contents of your waste, the designated treatment facility can more easily and efficiently process your waste. In return you receive the peace of mind knowing that your hazardous waste management procedures have improved by simply taking the time to crack the manifest code!

Visit EPA's web site on Hazardous Waste Manifest System.  Also, there is an informative training video available from the Printer's National Environmental Assistance Center.

July 27, 2006

Do not forget to order your new uniform manifests. The federal regulation that replaces current state manifests with the new uniform manifests goes into effect September 5, 2006. The Uniform Hazardous Waste Manifest regulation standardizes the manifest form for the entire country. The new regulation also ensures each manifest has a unique, sequential tracking number, better correlation with the U.S. Department of Transportation (DOT) regulations, and helps track manifest discrepancies. The standardized form will have fields that include wastes codes, an emergency response phone number and a manifest tracking number. If needed, international shipment information and hazardous waste report management method codes can be filled out on the manifest. The new form will no longer have a location for the Missouri generator identification number. You may still use state specific waste codes on the form - for example, in Missouri waste used oil has a code of D098. You may contact the approved printers or your current hazardous waste transporter to obtain the new manifests. You will no longer be able to order hazardous waste manifests from the Missouri Department of Natural Resources.

June 1, 2006

Manifest Update!

Printers for the uniform hazardous waste transportation manifests have been approved! Contact information for the newly approved printers is on the U.S. Environmental Protection Agency's manifest information. For more information on the changes to hazardous waste manifests, including when the switch to the new manifest will occur, please review our two previous listservs on the topic below.

April 13, 2006

The New Uniform Manifest

There are big changes coming down the road for your hazardous waste manifests. On September 5, 2006, your business will be required to use the new Federal Uniform Manifest.  According to the US EPA's website, fourteen companies as of March 27, 2006, have applied for approval to print the new uniform manifests. Although there are currently no approved printers for the uniform manifest, it is a good idea to start thinking about using up your current stash of manifests and scheduling a waste shipment before the September 5, 2006, date. If your business is a small quantity generator you will have 180 days (or 270 days if your waste is transported more than 200 miles) before you must ship again. If your business is a large quantity generator you will have 90 days before you must ship again. Because this is such a large, industry-wide change, it is a good idea for your business to be proactive. Bookmark the US Environmental Protection Agency's manifest information and check it frequently to see if printers have been approved. Once approved printers are available, order your manifests early to ensure you receive them by September 5, 2006. Contact your licensed hazardous waste transporter and to learn if they have new procedures or updates. It might be a good idea to avoid potential problems in the new system by scheduling your waste removal prior to the early September rush. As always, this listserv will notify you of any changes or updates.

E-Scrap Stakeholders Workgroup

If you are receiving this listserv, you have a computer. Electronic waste or E-Scrap is an important and complex issue. Our first E-Scrap Stakeholders Workgroup on February 24, 2006, was very successful. If you are interested in participating, know anyone who would be interested in participating, or would simply like to see what we are working on, visit E-Scrap Stakeholder Workgroup.  The next E-Scrap Stakeholder meeting is Wednesday, April 19, 2006, from 9:00 a.m. to 4:00 p.m. at the Elm Street Conference Center, 1738 E. Elm Street, Jefferson City, Missouri (see map for location). The primary purpose of the E-Scrap Stakeholder Workgroup is to determine the framework for how E-Scrap is disposed, reused, and recycled without threat to the environment and in an economically sustainable fashion. Please contact Mike Menneke or Heidi Rice at 573-751-3176 for more information.

Nov. 30, 2005

In case you hadn't heard, the Environmental Protection Agency (EPA) has overhauled the current hazardous waste shipping manifests. No longer will companies that operate in multiple states need to learn and use multiple types of state manifests.  The Uniform Hazardous Waste Manifest regulations standardizes the manifest form, insures each manifest has a unique tracking number, better correlate manifests with U.S. Department of Transportation (DOT) regulations and helps track manifest discrepancies. The standardized form will have fields that include wastes codes, emergency response phone number, manifest tracking number, international shipment information and hazardous waste report mangagement method codes. The new form will no longer have a location for the Missouri generator identification number. You may still use state specific waste codes on the form, for example in Missouri waste used oil has a code of D098.

Although no one is required to use the new uniform manifest until Sept. 5, 2006, we thought you might want to know about upcoming changes. Please continue to use up your current stock of manifests. Keep in mind that once Sept. 5, 2006, arrives you will no longer be able to use old manifests so you may not want to stock up! If you are about to run out of the old ones you may wish to switch over to the new form if available from your transporter or treatment facility.

EPA Links

This information may generate more questions. Please email your questions on manifesting and they will be addressed in future listservs.

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If you need further assistance, please email or contact the Department of Natural Resources' Hazardous Waste Program at 573-751-7560 or 800-361-4827.

Return to listserv topics at DNR Hazardous Waste Generator Archive.