UNIFORM HAZARDOUS WASTE MANIFESTS

Hazardous Waste Program fact sheet
07/2014
Division of Environmental Quality Director: Leanne Tippett Mosby
PUB2301

The Missouri Department of Natural Resources’ Hazardous Waste Program prepared this publication for generators, transporters and facilities that are involved in the shipment of hazardous waste and are required to use the Uniform Hazardous Waste Manifest. This publication summarizes some key points in the using the manifest.  This publication should not be used in place of state and federal laws nor as a substitute for training needed for the completion a Uniform Hazardous Waste Manifest.

What is the Uniform Hazardous Waste Manifest?
A manifest for shipping hazardous waste is a key component in a system for tracking hazardous waste shipments from the generator’s location to the off-site waste management facility, that will store treat or dispose of the waste. It is part of a system of forms, reports and procedures designed for 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 Uniform Hazardous Waste Manifest 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 the Department of Transportation, the U.S. Environmental Protection Agency and the state. 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.

Sept. 5, 2006 was the effective date for using the new Federal Uniform Hazardous Waste Manifest. The U.S. Environmental Protection Agency’s (EPA’s), goal in modifying the manifest was to reduce paperwork requirements on generators, transporters and treatment, storage and disposal facilities (TSDFs) that use the manifest.

The EPA adopted regulations of the United States Department of Transportation (USDOT) governing the transportation of hazardous materials. Hazardous waste is a hazardous material.   USDOT’s hazardous materials transportation regulations encompass the transportation of hazardous waste and regulate intrastate and interstate transportation of hazardous waste.  USDOT regulations are fully applicable and enforceable on all transportation of hazardous materials / hazardous waste transportation activities.  USDOT regulations are found at 49 Code of Federal Regulations Parts 100-179 and EPA hazardous waste regulations in 260-275.  The USDOT’s Pipeline and Hazardous Material Safety Administration provides the framework of regulations regarding transportation and EPA adds to this basic set of rules for hazardous materials that are also hazardous wastes. All regulations apply unless expressly exempted within the EPA and USDOT regulations.

Uniform Hazardous Waste Manifests create consistently and uniformity in the shipment of hazardous waste nationwide.

More information may be obtained at http://www.dnr.mo.gov/env/hwp/enf/manifests.htm.

Why is this important to know?
This “cradle to grave” tracking system involves several types of businesses and individuals. For example, are you a generator? Do you package the waste or are you responsible for the manifest paperwork? Do you drive the truck that will eventually deposit the hazardous waste at an appropriate treatment, storage and disposal facility? If you are a generator, transporter or facility involved in the shipment of hazardous waste in Missouri you must use the uniform hazardous waste manifest to record shipments of hazardous waste unless your company meets the exception found under 40 CFR 262.20(e) and 40 CFR 263.20(h) et al.

Where do I obtain Hazardous Waste Manifests?
Manifests are available from by any printer approved by EPA. A list of the approved printers is available at the following EPA Web site: www.epa.gov/epawaste/hazard/transportation/manifest/registry/printers.htm

For manifest frequent questions involving how many waste codes - http://www.epa.gov/osw/hazard/transportation/manifest/faqs4-07.htm

Are there any state specific requirements?
State specific waste codes for which there are no federal equivalents should be used on the manifest when applicable. They include:

All in-state and out-of-state treatment, storage and disposal facilities are required to send appropriate copies of the manifest to Missouri Department of Natural Resources’ Hazardous Waste Program, P.O. Box 176, Jefferson City, MO 65101.

What are the basic generator requirements for using the manifest?
Generators of hazardous waste shall follow the step-by-step instructions  located on the back of the manifest http://www.epa.gov/epawaste/hazard/transportation/manifest/pdf/man-inst.pdf

These instructions include providing an accurate USDOT description of the waste. Waste quantities entered are to be based on actual measurements or reasonably accurate estimates of actual quantities shipped. Container capacities are not acceptable. If the unit of measure in item 12 is in gallons or liters, the specific gravity shall be listed in item 14.
Generators of hazardous waste must designate a treatment, storage and disposal facility on the manifest to receive their waste. If this treatment, storage and disposal facility cannot accept the waste, the generator should designate an alternate facility.

The generator will provide appropriate copies of the manifest to all transporters and facilities involved in the shipping process.

The generator must sign and date the shipper’s certification and waste minimization statement, located in item 15 of the manifest and give the remaining copies of the manifest to the first transporter.
If the generator has not received a copy of the completed manifest by the treatment, storage and disposal facility within 35 days of the original shipment date, the generator must file a Generator Exception Report with the Missouri Department of Natural Resources within 45 days of the original shipment date. A copy of the generator exception report is available at  http://dnr.mo.gov/forms/780-0651-f.pdf Generators of hazardous waste must retain copies of all hazardous waste manifests for a period of three years from the date of shipment.

What are the basic transporter requirements for using the manifest?
Transporters shall follow the step by step Instructions for Transporters located on the back of the manifest.

A transporter may not accept hazardous waste from a generator without a hazardous waste manifest.

The initial transporter must sign and date the acknowledgement of receipt in item 17 of the manifest. All subsequent transporters must follow the appropriate instructions found on the back of the manifest or at the following link http://www.epa.gov/epawaste/hazard/transportation/manifest/pdf/man-inst.pdf and must sign and date accordingly.

The transporter that delivers the waste to the facility must ensure the hazardous waste manifest is signed in item 20 before relinquishing the waste.

If the waste is transported by rail, the first rail transporter must sign and date the manifest and forward the manifest to the next non-rail transporter, the designated facility or the last rail transporter.

Transporters of hazardous waste must retain copies of all hazardous waste manifests for a period of three years.

What are the basic designated facility requirements for using the manifest?
Designated facilities should follow the step by step Instructions for Owners/Operators of Treatment, Storage, and Disposal Facilities located on the back of the manifest. The designated facility must sign and date the certification of receipt of materials in item 20 of the manifest. Within 30 days of the date of delivery, the designated facility should send a copy of the completed manifest to the generator. The treatment, storage and disposal facility should note any significant manifest discrepancies as listed below on item 18a of the manifest:

1. Significant differences between the quantity designated on the manifest and the actual quantity measured at the facility include:

a. Greater than 10 percent in weight for bulk waste.
b. Variation in piece count for non-bulk waste (example: one less drum than is listed on the manifest).

2. Significant differences between the type of waste designated on the manifest and the type of waste determined after waste analysis. Please note that significant differences in quantity and type should be discussed between the designated facility and generator after the facility has determined this discrepancy. If the discrepancy is not resolved within 15 days of receiving the waste, the designated facility must submit a manifest discrepancy report to the department describing the discrepancy, attempts to reconcile with the generator and a copy of the completed manifest.

3. Rejected wastes, including full and partial rejections.

4. Container residues that exceed EPA’s definition of “empty.”


See the flow chart at the end of this fact sheet for the methods of manifesting rejected wastes and residues

If the designated facility receives hazardous waste without an accompanying manifest, the facility should prepare an un-manifested waste report with the following information.

  1. The name, EPA identification number and address of the generator, transporters and designated facility involved in the shipping process.
  2. The date the facility received the waste.
  3. A description and quantity of the un-manifested waste.
  4. The method of treatment, storage or disposal of the waste.
  5. The certification signed by an authorized representative of the designated facility.
  6. An explanation of why the waste was un-manifested.

All in-state and out-of-state designated facilities must send in a copy of the completed manifest to the Missouri Department of Natural Resources’ Hazardous Waste Program, P.O. Box 176, Jefferson City, MO 65101. Designated facilities must retain copies of all hazardous waste manifests for three years.

What are the differences between waste codes and management method codes?
Waste codes are designated by EPA and indicate the hazardous waste being shipped. They include listed hazardous wastes and characteristic hazardous wastes. The uniform hazardous waste manifests accommodates up to six waste codes for each waste stream. This does not mean there will always be multiple descriptions for each waste. The extra fields simply allow for a more detailed description of wastes that may be characterized by more than one or two waste codes. A list of hazardous waste codes is available at www.epa.gov/osw/inforesources/data/br91/na_apb-p.pdf.

Management Method Codes are filled out by a representative of the designated facility.  Management Method Codes and information about the appropriate use of these codes are available at http://www.epa.gov/osw/hazard/transportation/manifest/pdf/codes.pdf

Link what qualifies as a empty container EPA - 40 CFR 261.7 Residues of hazardous waste in empty containers. http://www.gpo.gov/fdsys/pkg/CFR-2013-title40-vol27/xml/CFR-2013-title40-vol27-sec261-7.xml

Regardless of what qualifies as a RCRA empty container, if said container is offered for shipment that container must still meet the USDOT requirements for empty packaging. 49 CFR 173.29 Empty Packaging http://www.ecfr.gov/cgi-bin/text-idx?SID=9d6f90f68c10a4c626ac3ef0c5968e1e&node=49:2.1.1.3.9.2.25.12&rgn=div8


Should I use gross or net weight on the manifest?
The manifest instructions specifically state the quantity of hazardous waste recorded on the manifest should be based on “actual measurements or reasonably accurate estimates of actual quantities shipped.” The container capacities should not be used. If possible, the weight of only the waste itself should be recorded in item 11 on the manifest.

Can I use the Hazardous Waste Manifest to ship material other than hazardous waste?
Yes, because the hazardous waste manifest is a modified bill of lading and conforms to all USDOT shipping paper requirements, you are allowed to use this form to ship material other than hazardous waste. If you are shipping your hazardous waste with non-hazardous waste/ material you should designate this by listing all hazardous materials/waste first, placing an “X” before the shipping description or highlighting all hazardous material/waste listed on the manifest.

What’s this I hear about an e-manifest?
EPA is implementing an electronic manifest tracking system that will affect hazardous waste manifest users at the national level. This new e-manifest tracking system will most likely be optional. The e-manifest is not yet an option in Missouri. News and facts about the e-manifest can be found at the following link http://www.epa.gov/epawaste/hazard/transportation/manifest/e-man.htm . Should the e-manifest be implemented in Missouri, a publication sheet will be created for assistance in its use.

How to Obtain Copies of Hazardous Waste Laws and Regulations?

For More Information
Missouri Department of Natural Resources
Hazardous Waste Program
Compliance/Enforcement Section
P.O. Box 176
Jefferson City, MO 65102-0176|
800-361-4827 or 573-751-2032
www.dnr.mo.gov/hwp