Hazardous Waste Manifest Requirements
This fact sheet answers general questions and provides basic information on hazardous waste manifest requirements. Although it is provided as helpful guidance, this fact sheet is not intended to supersede the applicable regulations. The hazardous waste manifest requirements are found in Section 22a-449(c)-102 of the Regulations of Connecticut State Agencies ("RCSA"), incorporating Subparts B and D of Title 40 of the Code of Federal Regulations part 262 (40 CFR 262).
- As of September 29, 2015, generators are no longer required to submit a copy of their completed manifest to DEEP. There is a DEEP letter that documents this change in procedure.
- At the end of June, EPA will launch a new electronic manifest system (the "e-Manifest") that will largely replace the need for paper manifests. For more information, see EPA's e-Manifest Fact Sheets web page and e-Manifest web page.
When is a Hazardous Waste Manifest Required?
A generator who transports, or offers for transportation, hazardous waste for off-site treatment, storage or disposal must prepare a hazardous waste manifest to accompany such shipment. This includes both Large Quantity Generators and Small Quantity Generators. In addition, Connecticut’s requirements are more stringent than those at the federal level in certain ways. Most notably, small quantity generators in Connecticut are not exempted from hazardous waste manifest requirements for shipments of wastes that are returned for reclamation under a contractual agreement with the reclaimer. In addition:
- A hazardous waste manifest is required for certain wastes that are regulated as hazardous in one state but not another. For example, a hazardous waste manifest is required for the shipment of a waste that is not hazardous in Connecticut, but is being shipped to a state where it is regulated as hazardous waste. An example of this would be a shipment of used oil being sent by a generator in Connecticut to a facility in Massachusetts (which regulates used oil as hazardous waste). Similarly, a hazardous waste manifest is also required for the shipment of a waste that is not hazardous in another state and is being sent to a facility in Connecticut, where it is regulated as hazardous waste. An example of this would be a waste that is hazardous for chromium (EPA Waste Code D005), and the chromium is primarily in the trivalent form.
- Some facilities that accept non-RCRA hazardous wastes ("Connecticut-Regulated Wastes) require the use of a hazardous waste manifest for the shipment of these wastes. However, copies of manifests for CR02-CR05 wastes should not be submitted to the Department. There is a DEEP letter that documents this policy.
- Hazardous waste manifests are also required for wastes containing regulated quantities of polychlorinated biphenyls, or "PCBs." For more information on the requirements for the management of PCB wastes, including PCB manifest requirements, see the DEEP's PCB web page and the US EPA's PCB web page.
When is a Hazardous Waste Manifest NOT Required?
In general, a hazardous waste manifest is not required for any waste that is not a hazardous waste. Hazardous waste manifests are also not required for certain types of hazardous waste. More specifically a hazardous waste manifest is not required for:
- Shipments of non-RCRA hazardous wastes ("Connecticut-Regulated Wastes). (as noted above, however, some destination facilities may require it).
- Shipments of used oil (provided that the used oil is not contaminated with hazardous waste).
- Shipments by Conditionally-Exempt Small Quantity Generators, provided that they do not accumulate more than 1,000 kg (2,200 lbs.) of hazardous waste or 1 kg of any acute hazardous waste at the site.
- Shipments of certain types of hazardous wastes that are exempted from hazardous waste manifesting requirements. The two most common examples include Universal Wastes, and Lead-Acid Batteries that are managed under the requirements of RCSA Section 22a-449(c)-106(c).
How May I Obtain a Hazardous Waste Manifest?
Many waste transporters provide hazardous waste manifests for the waste shipments that they handle. Generators may also obtain hazardous waste manifests from EPA-Approved Registered Printers of manifest forms. EPA has a list of such printers on their website.
How Should I Prepare a Hazardous Waste Manifest?
Detailed instructions on how to fill out a hazardous waste manifest and distribute copies may be found on the US EPA's Hazardous Waste Manifest web page.
However, to summarize, the generator must:
- completely and legibly fill out, and assure the correctness, of all items;
- sign the manifest certification by hand;
- obtain the handwritten signature of the transporter and the date of waste acceptance on the manifest; and,
- retain and distribute copies as indicated in the manifest instructions referenced above.
Note: Many transporters and receiving facilities pre-fill hazardous waste manifests for their customers. While this practice is acceptable, it is still the responsibility of the generator to check the information in the manifest form and confirm that it is complete and accurate. When a generator signs a hazardous waste manifest, the generator is certifying the information provided in the manifest form. If any of the information in the manifest form is found to be incomplete or inaccurate, the generator may be subject to enforcement, including the possibility of civil or criminal prosecution and penalties.
Must I Keep Copies of My Hazardous Waste Manifests?
A generator must retain a signed copy of the manifest for each shipment for at least three years. The original copy serves this purpose until he/she receives a signed copy from the designated (receiving) facility as confirmation of delivery. The copy received from the designated facility should be kept by the generator for at least three years from the date the waste was accepted by the initial transporter.
Additional record keeping requirements apply if a generator does not receive confirmation from the designated facility.
If a large quantity generator does not receive a confirmation of delivery (a signed copy of the manifest from the designated facility) within 35 days of the date the waste was accepted by the initial transporter, he/she is required to contact the transporter and/or the designated facility to determine the status of the hazardous waste.
If the large quantity generator does not receive a confirmation of delivery (a signed copy of the manifest from the designated facility) within 45 days of the date the waste was accepted by the initial transporter, he/she must submit an Exception Report to the Commissioner. The Exception Report shall include: (1) a legible copy of the manifest for the waste for which there is no confirmation of delivery; and (2) a cover letter signed by the generator or the generator’s designate detailing the efforts taken to locate the hazardous waste in question and the results of such efforts.
If a small quantity generator does not receive a confirmation of delivery (a signed copy of the manifest from the designated facility) within 60 days from the date the waste was accepted by the initial transporter, he/she must submit to the Commissioner a legible copy of the manifest with some indication that the confirmation of delivery was not received.
Where May I Get Additional Help on The Use of Hazardous Waste Manifests?
If, after reading this fact sheet and the manifest instructions, you still have any questions on hazardous waste manifests, call DEEP's toll-free Hazardous Waste Compliance Assistance Line at 1-888-424-4193, or send us an email.
Are There Other Requirements I Should Know About?
The hazardous waste regulations include requirements designed to ensure that hazardous wastes are properly treated before being land-disposed or processed into products that are placed on the land. Known as the Land Disposal Restrictions ("LDRs"), these requirements may be found in 40 CFR 268, and include provisions requiring generators to fill out an LDR notification form to accompany waste shipments. Waste haulers routinely offer an LDR form to their clients whenever it is needed. If you have any questions on the LDR requirements, see US EPA's LDR web page. You may also call DEEP's toll-free Hazardous Waste Compliance Assistance Line at 1-888-424-4193, or send us an email.
This overview is designed to answer general questions and provide basic information. You should refer to the appropriate statutes and regulations for specific regulatory language. It is your responsibility to comply with all applicable laws and regulations.
Content Last Updated on January 30, 2020