The U.S. EPA has established
a nationally standardized manifest form to improve the tracking
of hazardous waste shipments. The national
form replaced the various federal and state forms previously
in use on September 5, 2006. Among other benefits, the new manifest
form will enhance reporting of international waste shipments (exports
and imports) by identifying the port of entry/exit.
EPA also proposed to make
the manifest tracking form electronic (e-manifest). However, that
effort is delayed indefinitely due to unresolved technological
Subtitle C of the Resource
Conservation and Recovery Act (RCRA) required EPA to establish
a manifest system to track shipments of
hazardous waste from a generator's site to the site where the hazardous
waste is sent to be managed (that is, cradle-to-grave). EPA published
regulations for a manifest system on February 26, 1980 and for more
than 20 years hazardous waste generators and transporters have been
required to use this system. The central element of the manifest
system, the manifest form (EPA form
8700-22), provides a complete paper trail of a waste's progress
from a generator through treatment, storage, and disposal. It identifies
the type and quantity of the hazardous waste being shipped, and contains
a generator's certification of waste minimization practices. Each
waste handler must return a copy of the manifest to the generator.
A missing form alerts a generator to investigate and find the waste.
If the waste cannot be found, then the generator notifies either
EPA or the state agency for appropriate action.
Soon after the 1980 regulations
became effective; more than 20 states developed and required their
own manifest forms. These forms met
the minimal Federal requirements but also required additional state
information. Significant confusion and compliance difficulties resulted
from the differing manifest requirements. Often, it was necessary
for generators to prepare multiple manifests for interstate shipments
to satisfy the requirements of the states through which the hazardous
waste traveled. Therefore, in 1984 EPA promulgated a Uniform Hazardous
Waste Manifest form and procedures for its use. Under this system,
EPA designed a form with both mandatory and state optional blocks
(upper right-hand corner of form), the latter of which allowed states,
at their option, to require the entry of additional specific information
to serve their state's regulatory needs. Twenty-three states
adapted the form with their own letterheads and added their
own data requirements. The 1984 form (and state versions) was an
improvement in terns of standardization; it eliminated the need for
using multiple forms for interstate transport of hazardous waste.
However, certain important aspects of waste shipments (e.g., international)
were not adequately addressed by the form and there remained significant
variation among state forms due to the optional blocks.
On March 4, 2005, EPA
published new rules regarding the manifest system, including a
standardized manifest form. The new system reduces
or eliminates many of the variabilities in state manifest requirements. For
example, the new manifest form uses check boxes and adds fields to
better track "difficult" shipments, such as container residues,
rejected wastes, and transboundary shipments. The
new form is also intended to make it easier to collect data for hazardous
waste reporting. The manifest will be printed to precise EPA specifications
that ensure uniformity and each form will carry a unique preprinted
manifest tracking number. The same manifest form will be
used by every jurisdiction beginning September
Affected facilities can
obtain new forms from any source that has registered
with the EPA to print and distribute the form. EPA will not distribute
forms. Rather, the Agency will oversee the printing requirements
and ensure that registered printers follow them. States may also
register to print the new form, but State rules cannot establish
the state as the exclusive source of forms. An affected facility
can use a manifest from any registered source.
Impact on International Shipments
The new manifest form has an international shipments field (block
16), which includes:
- check boxes to indicate if the waste is being imported to the
U.S. or exported from the U.S.,
- a space to indicate the port of entry/exit, and
- a space for the transporters
signature and "date leaving U.S." (for
While revising the manifest
system, EPA considered adding a new requirement for importers to
leave a copy of the manifest with U.S.
Customs at the port of entry. However, this requirement was dropped
and a new provision was added that requires the receiving facility
to mail a final signed copy of the manifest to EPA's International
Compliance Assurance Division in Washington, DC.
Changes to the Manifest Form and Continuation Sheet
At first glance, the new
manifest form and continuation
sheet look very similar to current federal and state forms. However,
there are a number of significant changes that eliminate unnecessary
aspects of the existing forms, help to minimize ambiguities, and/or
improve waste tracking. The following are key changes:
- Elimination of state optional data fields, including state manifest
number, state ID numbers (generator, transporter, TSDF), phone
numbers, and additional descriptions for materials.
- Addition of an international
waste shipment field (block 16). See Impact
on International Shipments
- Addition of a preprinted manifest tracking number (block 4) that
replaces the manifest document number and state manifest number.
- Addition of a generator's site address block (in addition to
the existing requirement for generator's name and mailing address
in block 5).
- Addition of an emergency response phone number field (block 3).
- Addition of a hazardous waste
report management method field (block 19) that must be completed
by TSDFs. The codes relate to biennial waste reporting
codes and reflect the manner in which the TSDF handles the waste.
- Expanded the waste code field
(block 13) to allow for entry of up to six federal and state
waste codes. Any combination of state and federal waste codes
can be entered, but instructions specify that, "state waste
codes that are not redundant with federal codes must be
entered". Space is limited to six entries, so federal codes
most representative of the properties of the waste should be
- The existing Discrepancy block (block 18) has
been significantly changed to allow tracking of rejected
and forwarded wastes and regulated container residues. Regulated
container residues are residues that exceed the quantity limits
for "empty" containers and as such remain subject to
regulation and tracking requirements. Block18a is used to indicate
the type of discrepancy. Block 18b is used to specify alternate
facility information when waste is rejected back to the generator
or forwarded to another facility. Block 18c is used by the alternate
facility to sign for receipt of rejected or forwarded waste.
Additional Changes to the Manifest System
The new manifest rules
go beyond changes to the manifest form. There
are also changes or in some cases clarification to other aspects
of the manifest system. Some key items include:
- Clarification on use
of fractions and decimals for entering waste quantity data. EPA does not want generators to enter decimals
or fractions on the manifest form. Accurate data can be reported
without use of decimals and fractions by properly selecting units
of measure (e.g., report in pounds instead of tons).
- Generators must report
quantities of waste shipped accurately. It
is unacceptable to report quantities based on the capacity of containers
when the containers are not completely filled. It is the responsibility
of the TSDF to report discrepancies concerning waste quantities
shown on the manifest and those actually received.
- Procedures for TSDF to follow in regard to the manifest form
in the event that they reject a waste shipment.
- Many years ago the DOT definition of bulk packaging
was based on 110 gallons and RCRA regulations used the same number. DOT
subsequently changed from 110 to 119 to be consistent with international
standards. The manifest rule includes minor adjustments to RCRA
regulations to conform to the DOT standard.
What is the Status
of the E-Manifest?
When modifications to
the Hazardous Waste Manifest System were proposed in May 2001,
those modifications covered both the revised manifest
form and the implementation of an electronic manifest system (e-manifest). However,
on March 4, 2005, the uniform hazardous waste manifest rule was finalized,
but not the e-manifest component. EPA said that too many significant
issues were raised in response to the e-manifest proposal and that
the agency had to continue analysis and outreach before the proposed
system could be finalized.
For more than 20 years, the hazardous
waste manifest system has relied on the creation of a paper trail
to track hazardous waste shipments from cradle-to-grave. Waste
generators create multicopy manifest forms to show the transportation
routing of their waste shipments and the composition and quantity
of the materials being shipped. Each handler signs the manifest
by hand, until it is signed by the final waste management facility
to show the waste shipment was received. Copies signed by all parties
are retained in company files, and the final copy verifying receipt
by the treatment, storage and disposal facility (TSDF) is mailed
back to the generator to close the tracking loop. About 28 states
also collect manifests from generators and TSDFs, and the data
are manually keyed into state tracking databases to help oversee
waste management trends and assess fees. Because of the volume
of manifests circulated each year (more than 2.5 million) and the
number of copies that must be signed sequentially and retained
in files for inspection, the manifest system produces some of the
largest paperwork burdens in the U.S. Compliance with the manifest
system costs waste handlers and states more than $193 million annually.
For this reason, EPA has been pursuing for several years a project
that would transition the manifest from a paper-based system to
an electronic approach.
Under EPA's e-manifest plan, that agency would oversee the work
of a private contractor who would develop and implement the e-manifest
system. The contractor would be reimbursed for the system's
costs from fees assessed on hazardous waste generators using the
As of September 5, 2006,
the new standardized manifest form (EPA Form 8700-22) and its continuation
sheet (EPA Form 8700-22A) must
be used in every state to track hazardous waste shipments. There
will be no state variations of the new federal form and states may
not require information to be included on the form that is in addition
to that required by federal rules. That said, some differences between
states may exist with regard to use of the form. These differences
- Some states designate
used oil (or other non-hazardous federal wastes) as a hazardous
waste and require use of the manifest
these wastes. Generators must determine whether the origination
or consignment state require use of the manifest system for these
regulations specify exceptions that preclude use of a manifest.
not required to recognize
- Under federal rules CESQGs
are exempt from the manifest system. Some states do not have a
CESQG category and/or
do not allow
from the manifest system.
- Under federal rules, under
certain circumstances, SQGs are exempt from the manifest system
when shipping waste for
Not all states have adopted this exemption
field 19 of the new manifest form must be used to enter state-specific
hazardous waste codes, if they exist (this is
a state variation only
in the sense that state codes vary).
- The new manifest has
six copies or pages. Federal rules require that signed manifest
copies are retained/distributed
- generator retains copy
6 and copy 3, the latter of which is sent to the generator by the
TSDF after the waste arrives
- transporter (retains copy
- TSDF (retains copy 4,
mails copy 3 to generator).
- States may require that copies of the manifest be distributed
by the TSDF to the origination and destination state
rules require LQGs and SQGs to perform certain activities and/or
if they have not
received a signed returned copy of the
manifest from the designated facility
within given time periods (exact rule
and time periods varies by generator category). Some states have
reporting rules that are generator-category
rules require that manifests and exception reports must be kept
for a period
of three years
(extended in event
enforcement action). Some states require
longer retention periods.
The table below indicates
for each state, where variation from federal rules exists. (Click on the "X" to review variation.)
The following include
related documents and web pages that provide further explanation
regarding EPA's modifications to the hazardous
waste manifest system.
on EPA's web site on where to obtain manifest forms, and guidance
on completing the forms, including
Training Video. A new training video that
introduces the new manifest form, highlights the differences between
and the previous manifest form.
Federal Manifest Form
EPA web page: Hazardous Waste Manifest System