A hazardous waste manifest is the shipping paper for hazardous waste. The manifest travels with the hazardous waste from the point of generation through transportation to the final treatment, storage, and disposal facility (TSDF) or other receiving facility. Each party in the chain of shipping, including the generator, signs (either by hand or electronically) and keeps a manifest copy, creating a “cradle to grave” tracking of the hazardous waste.

Hazardous waste manifests are required by the EPA for the transport of all shipments of hazardous waste, including rejected shipments. The hazardous waste manifest supplies the essential data to properly load, store, and handle hazardous wastes and provides necessary information to enable emergency personnel to safely handle a problem during an accident or an emergency.

e-Manifest System

The e-Manifest system is the means through which the e-Manifest may be obtained, completed, transmitted, and distributed to users of the e-Manifest and to regulatory agencies (i.e., the EPA and state environmental regulatory agencies). In the e-Manifest system, manifests are created by the generator electronically and transmitted by each party electronically. Once an e-Manifest is created by a generator, the rest of the copies (for transporters and receiving facilities) must also be electronic.

Who’s Covered and Exemptions

Everyone who is involved with the shipment of hazardous waste must comply with the manifest requirements. Once the transporter accepts the waste shipment from a hazardous waste generator, the transporter, all subsequent transporters, and the receiving facility must all comply with the rules of the manifest system. Among the transporter activities the EPA exempts from the hazardous waste manifest system requirements are:

• The transportation of hazardous waste within contiguous property; and
• The transportation of hazardous waste from a hazardous waste generator (SQG), provided the SQG is exempt from the manifest requirements as part of a reclamation.

General Transporter Rules

Accessing the e-Manifest system. A transporter using the e-manifest system needs to install portable devices or other computer equipment on its transport vehicles in order to participate in the e-Manifest system. Access to the e-Manifest system can also be obtained from the equipment provided by a participating generator, by another transporter, or by a designated facility. In addition, each driver would need to be registered so that each can sign manifests electronically.

A transporter must not accept hazardous waste from a generator unless the waste is accompanied by a manifest hand-signed by the generator.

Before transporting the hazardous waste, the transporter must sign and date the manifest, acknowledging acceptance of the hazardous waste from the generator. The transporter must return a signed copy to the generator before leaving the generator’s property.

Rules During Transit

Keep forms with shipment. It is the transporter’s responsibility to ensure that the manifest accompanies the hazardous waste. If the hazardous waste is to be exported under the terms of a consent issued by the EPA to the exporter, the transporter must ensure that a movement document that includes all required information also accompanies the hazardous waste. In the case of imports occurring under the terms of a consent issued by the EPA to the country of export or the importer, the transporter must ensure that a movement document that includes all required information also accompanies the hazardous waste.

Transferring the waste. If the hazardous waste is transferred from one transporter to another or is delivered to the designated facility, the transporter must:

• Obtain the date of delivery and the handwritten signature of the next transporter to accept the shipment or of the owner or operator of the designated facility on the manifest.
• Retain one copy of the manifest for 3 years from the date the hazardous waste was accepted by the initial transporter.
• Give the remaining copies of the manifest to the accepting transporter or designated facility.

Paper manifest copy or printed copy of the e-Manifest. Because the DOT hazardous materials regulations concerning shipping papers for carriage by public highway require transporters of hazardous materials to carry a paper document, a hazardous waste transporter must carry one printed copy of the e-Manifest on the transport vehicle. The DOT requires that this printed e-Manifest copy (or the paper copy if the paper manifest is still allowed to be used) be stored in such a specific manner near the transporting vehicle’s controls so that it is readily available to, and recognizable by, authorities in the event of an inspection or accident.

Rules for Waste Delivery

Transporters must deliver the entire quantity of waste accepted from a generator or from another transporter to one of the following:

• The designated facility listed on the manifest
• The alternate designated facility if an emergency prevents delivery
• The place outside the United States designated by the generator
• The next designated transporter