Hazardous waste manifest

Scope

The Uniform Hazardous Waste Manifest (EPA Form 8700-22) is designed to track hazardous waste from the generator through each transporter to the off-site waste management facility that ultimately receives the waste. The system allows generators to confirm delivery and provides EPA and state agencies with oversight to ensure that hazardous waste is not lost, mismanaged, or improperly disposed.

Anyone who handles the hazardous waste including generators, transporters, and designated facilities must sign the manifest.

The manifest is regulated jointly by EPA under RCRA and the U.S. Department of Transportation (DOT) as a hazardous materials shipping paper. It contains detailed information on the waste type, quantity, EPA waste codes, and handling parties. Each manifest has a unique 12-digit manifest tracking number.

EPA’s e-Manifest system launched on June 30, 2018. While the information required on the manifest remains the same, e-Manifest allows manifest data to be electronically submitted, stored, and accessed through EPA’s RCRAInfo system. Generators may still use paper manifests; however, receiving facilities are responsible for submitting final signed manifests to EPA electronically.

New EPA Manifest Rule (Third e-Manifest Rule): EPA finalized the Third e-Manifest Rule on July 26, 2024, as part of its ongoing effort to modernize the hazardous waste manifest system and reduce reliance on paper records. Under the Third e-Manifest Rule, EPA revised the Uniform Hazardous Waste Manifest (EPA Form 8700-22) and continuation sheet (EPA Form 8700-22A) to transition from the traditional 5-copy manifest to a new 4-copy manifest. The revised 4-copy manifest:

• Eliminates the former “designated facility copy”
• Relies on electronic submission to EPA as the official record
• Allows designated facilities to retain records electronically rather than in paper form

Compliance Date: EPA established January 22, 2025, as the date on which use of the new 4-copy manifest would become mandatory for paper manifest users, but prior to that date, EPA announced a temporary enforcement discretion policy. As a result:

• EPA will continue to accept the obsolete 5-copy manifest after January 22, 2025, until further notice;
• EPA has committed to providing at least 90 days’ advance public notice before it stops accepting the 5-copy manifest; and
• During this transition period, both the 4-copy and 5-copy paper manifests are acceptable

Once fully implemented, the revised 4-copy manifest will be distributed as follows:

• Page 1 (Top Copy): Submitted by the designated facility to EPA’s e-Manifest system
• Page 2: Returned by the designated facility to the generator
• Page 3: Transporter copy
• Page 4 (Bottom Copy): Generator’s initial copy

Regulatory citations

• 40 CFR 262 Subpart B — Manifest requirements applicable to small and large quantity generators
• 40 CFR 262.40 — Recordkeeping
• 40 CFR 262.42 — Exception reporting
• 40 CFR 263 Subpart B — Compliance with the manifest system and recordkeeping [for transporters]
• 40 CFR 264 Subpart E/265 Subparts E — Manifest system, recordkeeping, and reporting [for designated facilities]

Key definitions

• Contact person: A person who is knowledgeable about the waste being shipped and accepts responsibility for answering questions about it in an emergency. A person listed as a contact must be reachable 24-hours per day while the waste is being shipped.
• Continuation sheet: An optional additional page for the manifest if the generator needs more room to accurately fill out the manifest. (Form 8700-22A)
• Designated facility (also called the receiving facility): The treatment, storage, and disposal facility that received the hazardous waste from the generator. These facilities may be approved to receive hazardous wastes or they may be approved for state-specific wastes only.
• Electronic manifest system (e-Manifest): A system of software applications and centralized EPA database to track waste shipments electronically. Generators may still elect to use paper copies of the manifest.
• e-Manifest user fees: The monetary charges associated with the manifest system. Fees will be higher for paper manifests than for electronic manifests. EPA will send a monthly invoice to the designated facility, which is expected to pass the costs along to generators.
• Exception reporting: The generator has not received a signed copy of the manifest back from the designated facility. LQGs that do not receive a copy from the designated facility within 45 days must attempt to contact the facility. If that doesn’t resolve the problem, they must file an Exception Report with the state. SQGs that do not receive a signed copy of the manifest from the designated facility within 60 days must send a copy of the manifest to EPA or their state with a note stating they did not receive confirmation of delivery.
• Hazardous waste generator: The facility that generates (produces) a hazardous waste. There are three distinct hazardous waste categories:
  • Very small quantity generators (VSQGs) are minimally regulated.
  • Small quantity generators (SQGs) must comply with basic hazardous waste management regulations.
  • Large quantity generators (LQGs) are highly regulated.
• Hazardous waste transporter: The company used to ship waste from the generator to the final destination. The transporter must meet all state and federal EPA and DOT hazardous materials requirements and obtain an EPA ID number.
• Hybrid manifest: A combination of paper and electronic manifests.
• Management method codes: The codes that describe the type of hazardous waste management system used to treat, recover, or dispose of a hazardous waste. These codes are entered on the manifest by the designated facility.
• RCRAInfo: The website linked to the e-Manifest system.
• Uniform Hazardous Waste Manifest: The formal name for the hazardous waste manifest, EPA Form 8700-22. The manifest consists of several copies that must be signed by the generator, transporter(s), and designated facility(ies). A copy signed by all the waste handlers must be returned to the generator.
• Waste codes: The number assigned to a particular type of hazardous waste (e.g., D001 for corrosive waste). Some states have waste codes assigned to state-only wastes.
• Waste minimization: The statement found on the hazardous waste manifest certifying that the waste generator has developed and is following a plan to reduce the amount of waste generated.

Summary of requirements

The summary below is divided into three parts, based on the type of user. Note that for electronic manifests, all handler copies (generator, transporter, and designated facility) will be collected and retained as copies of record by the e-Manifest system.

Hazardous waste generators must complete and sign the top copy of the hazardous waste manifest in order to ship waste offsite. This includes the following:

• Obtain an official Uniform Hazardous Waste Manifest. Paper manifests must be purchased from an EPA-approved printer. Electronic manifests may be downloaded or completed on EPA’s e-Manifest website. Note: Generators must register on the e-Manifest system if they wish to sign manifests electronically in the system.
• The manifest must contain a unique 12-digit tracking number (provided by the printer or EPA).
• Fill out the required fields on the manifest. The fields are the same on the paper and electronic versions.
• Train employees who sign the manifest. This training must cover the required elements of EPA’s hazardous waste regulations and DOT’s hazardous materials regulations.
• Sign the top copy of the manifest and offer the rest of the copies to the transporter. The transporter will sign a copy of the manifest and offer it to any subsequent transporters. Yet another copy will remain at the designated facility. The final copy is returned to the generator. This copy will be sent to federal EPA and the data will be entered into the public-facing database.
• The hazardous waste manifest must list a contact person who is available 24-hours a day to answer questions in an emergency.
• The manifest must list the facility’s EPA identification number.
• If a generator runs out of room to complete the manifest, a manifest continuation sheet (EPA Form 8700-22A) must be used.
• Once the generator receives the completed and signed manifest from the designated facility, the records must be kept for a minimum of three years.
• Exception Reporting:
  • A large quantity generator who does not receive a copy of the manifest with the signature of the owner or operator of the designated facility within 45 days of the date the waste was accepted by the initial transporter must contact the transporter and/or the owner or operator of the designated facility to determine the status of the hazardous waste.
  • Large quantity generator must submit an Exception Report if he has not received a copy of the manifest with the handwritten signature of the owner or operator of the designated facility within 60 days of the date the waste was accepted by the initial transporter. (Beginning on December 1, 2025, a large quantity generator must submit an Exception Report to the EPA e-Manifest system).
  • A small quantity generator of hazardous waste who does not receive a copy of the manifest with the handwritten signature of the owner or operator of the designated facility within 60 days of the date the waste was accepted by the initial transporter must submit a legible copy of the manifest, with some indication that the generator has not received confirmation of delivery, to the EPA e-Manifest system.

Transporters of hazardous waste:

• A transporter may not accept hazardous waste from a generator unless the transporter is also provided with a signed manifest form (EPA Form 8700-22, and if necessary, EPA Form 8700-22A).
• Before transporting hazardous waste, the transporter must sign and date the manifest acknowledging acceptance of the waste from the generator. Note: To sign an electronic manifest, the transporter must be registered in the e-Manifest system.
• The transporter must return a signed copy to the generator before leaving the generator’s property.
• The transporter who delivers the waste to another transporter or to the designated facility must:
  • Obtain the date of delivery and the handwritten signature of that transporter or of the owner or operator of the designated facility on the manifest; and
  • Retain one copy of the manifest; and
  • Give the remaining copies of the manifest to the accepting transporter or designated facility

• The transporter must deliver the entire shipment of hazardous waste to:
  • The designated facility listed on the manifest; or
  • The alternate designated facility, if the hazardous waste cannot be delivered to the designated facility because an emergency prevents delivery; or
  • The next designated transporter; or
  • The place outside the United States designated by the generator.

• If the load of hazardous waste is rejected by the designated facility, the transporter must retain a copy of the original manifest and obtain a new signed manifest from the rejecting facility.

Designated facilities: also known as treatment, storage, and disposal facilities, are the ultimate destination for hazardous waste. designated facilities play a large role in the hazardous waste manifest system. The following requirements apply to designated facilities:

• To handle electronic manifests, the designated facility must have an EPA Identification Number (even state-only waste facilities) and register with the e-Manifest system.
• Complete the designated facility’s portion of the manifest, including management method codes.
• Return a signed copy of the manifest (page 4) to the transporter.
• Within 30 days of receipt of the waste, submit page 1 of a paper manifest, or submit an image file of page 1 of the manifest, to federal EPA for data processing. (Note: Beginning June 30, 2021, EPA will not accept mailed paper manifests from designated facilities.)
• Retain a copy of each manifest for at least three years from the date of delivery.
• Pay the assessed fees from EPA at the end of each month.