New Manifest Requirement

Revised Uniform Hazardous Waste Manifests Effective Sept. 5, 2005

Federal Rule 70 FR 10776-10825 promulgated March 4, 2005, revised the Uniform Hazardous Waste Manifest that has been used to track hazardous waste from a generator's site to the disposal or treatment facility.

Brief History of Uniform Hazardous Waste Manifest

When the Resource Conservation and Recovery Act was passed in 1976, the regulations included creation of a manifest system for the purpose of tracking hazardous wastes "from the cradle to the grave" – or – from creation to destruction.  It wasn't until November 19,1980 that the use of a tracking document known as the "manifest" went into effect.  According to former EPA Administrator Douglas M. Costle The new nationwide tracking system aimed to put an end to the 'midnight dumper'-- who for years had been disposing of dangerous wastes as cheaply as possible by putting them down the drain and into sewers, into fields, and along the roadside--with no thought to the long-term public health or environmental effects.

In 1984 the current form of the Uniform Hazardous Waste Manifest was authorized.  While unshaded portions of this document are standardized throughout the United States, there are typically shaded areas that require certain state information to be provided.  States have been authorized to create their own manifests, that must include the information required by the federal government in the standardized format. Typically state manifest of the TSDF or disposal facility is the one that must be used for a a shipment of hazardous waste.  In the event the state to which the waste is being shipped has no state manifest, the manifest used is determined by the generator state.  If the generator state has no state manifest, usually any Uniform Hazardous Waste Manifest is authorized.  This means that many generators must keep a supply of several different manifests, and be trained in how to use each.

Revised Uniform Hazardous Waste Manifest

The new manifesting requirements will eliminate varying state manifests. All manifests will be "uniform" as the name suggests.

The revised manifest eliminates most sources of state-by-state variability in the contents (data fields) of the current RCRA manifest form, including the existing "state optional" boxes. State-specific hazardous waste codes will be permissible on the RCRA manifest form, but there will no longer be specific state required manifests.

The revised manifests also provide new check boxes and data fields to improve tracking of several unique shipments such as container residues, rejected wastes, and international waste shipments.

Manifest Document # eliminated / State Manifest Document # replaced: The revised Uniform Hazardous Waste Manifest eliminates the requirement for a Manifest Document # in item 1 (Generator's US EPA #/Manifest Document #).  The State Manifest Document # (old item "A") has been replaced with the Manifest Tracking Number (New Item 4).  This change is necessary because states are not the only agencies that can print manifests.  States, commercial printers, and waste handlers who register with EPA are authorized to print and distribute forms). The final rule requires that all manifest forms be printed to a precise federal printing specification to assure uniformity and quality. In addition, every form is required to have a unique preprinted manifest tracking number that will identify a waste shipment individually in all tracking systems. 

State ID #s and phone numbers eliminated: Requirement for state transporter and Facility ID and phone numbers, and state generator number (Old Items B-H) has been eliminated entirely. This information, if needed, is available by accessing the US EPA ID Number.  Note that the generator phone number is still required in Item 5 of the revised manifest.

Spaces provided for six federal and state waste codes: Spaces are maximum of six and state codes (Item 13).  State waste codes can be inserted only if they are not redundant with federal codes.  Codes listed should only be those that are most representative of the hazardous properties of the waste.

Standardized Management Method Code Box (new Item "19") replaces handling code (old item Item "K"): The revised manifest replaces the current waste "handling code" box with the "management method code" box.  The "management method code" box is eliminates the confusion of the "handling code" box that presently varies from state to state.  The "handling code" box will also be used for RCRA Biennial Reporting.  This should be a welcomed change to generators and government agencies who have repeatedly suggested that paperwork could be reduced if reporting requirements could be unified into fewer documents.

Additional descriptions eliminated:  The Box titled "Additional Descriptions for Materials listed above" (Item J) has been eliminated from the new manifest.

International shipment information added: A new section has been added for including information required for international shipments (Item 16).  Required information includes, indicating whether the material is being imported or exported, the port of entry/exit, and signature of transporter and date leaving U.S. (for exports only).

Effective dates

While use of the revised manifest is effective as of 9/5/05, the mandatory date of compliance is 9/5/2006.  The September 5, 2006 compliance date should give waste handlers to use up their stocks of the old forms.  In addition it will give companies and states time to apply to EPA Office of Solid Waste's registry, develop, print and distribute the revised manifest forms. Time will also be required to update databases, to address the rule's changes, and train personnel.