The Uniform Hazardous Waste Manifest is a document required by both the PHMSA/USDOT and the USEPA for the off-site transportation of hazardous waste and PCB Waste from its point of generation to its final treatment, recycling, or disposal.  But it’s not as easy as that…

• Federal regulations require the manifest be used for offsite transportation of hazardous waste generated by a Large Quantity Generator (LQG) and a Small Quantity Generator (SQG) of hazardous waste but not from a Conditionally Exempt Small Quantity Generator (CESQG).
• An authorized state may require the use of the uniform hazardous waste manifest from a CESQG.
• An authorized state may require the use of the uniform hazardous waste manifest for other wastes it has identified as hazardous.
• Any state may require the use of the uniform hazardous waste manifest for non-hazardous wastes.
• A waste transporter and/or the Treatment, Storage, and Disposal Facility (TSDF) may require the use of the uniform hazardous waste manifest as a condition of its acceptance.

The purpose of this article is to identify the responsibility of a hazardous waste generator to obtain the uniform hazardous waste manifest from a registered manifest printer.

Any regulated handler of a hazardous waste (generator, transporter, or TSDF) may obtain and complete the manifest for a waste shipment.  However, it is the responsibility of the Generator/Offeror of the waste to ensure not only that the information on the manifest is correct (see an example of the certification statement appearing on the manifest below) but that the manifest is purchased from a USEPA approved registered printer.  This was confirmed by an EPA response to my query:  “Is the generator of a hazardous waste responsible to ensure that the Uniform Hazardous Waste Manifest is obtained from an EPA approved registered printer?”  Their response:

While generators, particularly small generators, contract with transporters to assist them with various hazardous transportation activities, including manifest preparation, the generator is ultimately responsible for ensuring that the manifest used to initiate their shipment comes from an EPA approved registered printer. …

So, it is the responsibility of the hazardous waste generator to determine if its manifest is obtained from a USEPA approved registered printer.  How do you do this?  Refer to the USEPA’s Table of Approved Registrants:

Table of Approved Registrants

Each approved registered printer has its own three-letter manifest tracking number suffix (e.g. SKS for Safety-Kleen Systems, Inc.)  This suffix will be preceded by nine digits to complete the manifest tracking number found in item 4 of the uniform hazardous waste manifest and unique to each manifest.

After you have obtained your uniform hazardous waste manifest from a USEPA approved registered printer, you will need to ensure that every item on it is completed properly.  You will also need to ensure that every aspect of the hazardous waste’s classification, identification, packaging, labeling, marking – even the placarding of the truck – is done in compliance with the regulations of the USEPA, your authorized state, and the PHMSA/USDOT.  Does that seem like a lot?  Refer to the content of the certification statement found in item 15 of the uniform hazardous waste manifest:

GENERATOR’S/OFFEROR’S CERTIFICATION: I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name, and are classified, packaged, marked and labeled/placarded, and are in all respects in proper condition for transport according to applicable international and national governmental regulations. If export shipment and I am the Primary Exporter, I certify that the contents of this consignment conform to the terms of the attached EPA Acknowledgment of Consent.

I certify that the waste minimization statement identified in 40 CFR 262.27(a) (if I am a large quantity generator) or (b) (if I am a small quantity generator) is true.

More information:

• The waste minimization statement on the uniform hazardous waste manifest
• Training requirements for persons who sign the uniform hazardous waste manifest
• RCRA and state authorization