The Resource Conservation and Recovery Act (RCRA) requires you to document all shipments of regulated hazardous wastes. Domestic transportation is documented using Uniform Hazardous Waste Manifests, which are shipping documents prescribed by the US Environmental Protection Agency (EPA) which revises Manifest forms occasionally—including major changes back in 2006. Now EPA has acted again, to create an electronic manifest (“e-Manifest”) option that will take force once EPA finishes the web-page data system required to receive and manage electronic filings.
What Information Do Manifests Require
Most shipments of hazardous waste offsite for further management (usually by a RCRA-permitted treatment, storage and disposal facility (TSDF) or recycler) require a Uniform Hazardous Waste Manifest (EPA Form 8700-22) and, when necessary, one or more Continuation Forms (Form 8700-22A). Each Manifest requires the following information about the waste(s) in the shipment:
- Generator’s name, mailing address (and site address, if different), telephone number, and EPA ID Number
- Each transporter’s name and EPA ID Number
- Description of the nature and quantity of wastes shipped
- Name, address, telephone number, and EPA ID number of the facility designated to receive the waste
- Number and types of containers used
- Special handling instructions (if any)
- Any significant discrepancies between the waste as described on the manifest and the waste actually shipped
- Emergency response telephone number
- Generator’s/offeror’s certification of the accuracy of the information presented, and that a waste minimization program is in place.
Nationally, at least four copies of the manifest are required for each shipment. All are signed by the generator and presented to the initial transporter. Additional copies may be required if the shipment involves interim destinations or more than one transporter (and some states, such as California, require additional copies for the state’s hazardous waste regulators). The transporter signs the manifests to acknowledge receipt of the shipment, and returns one copy to the generator. The remaining copies accompany the shipment to its destination, where the recipient—typically, a TSDF—adds a signature acknowledging receipt. One signed copy is retained by the TSDF; another signed copy must be returned to the generator within 30 days; and other copies are returned to the transporter(s).
Collectively, all this paperwork is intended to ensure that every party knows its responsibilities, knows that every other party is authorized to participate, and knows that copies will be available to track down any non-compliance. But it adds up to a lot of paper – EPA estimates up to 5.6 million Manifests and Continuation Sheets annually, completed and tracked by 160,000 entities.