Hazardous waste manifest tips
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October 15, 2015
Hazardous waste manifest tips
By Elizabeth M Dickinson, JD, Senior Legal Editor - EHS

For several years we’ve all been hearing a lot about the electronic hazardous waste manifest (e-Manifest) that soon will replace the paper form, EPA Form 8700-22 and its continuation sheet, EPA Form 8700-22A. “Soon” has now been informally redefined by the Environmental Protection Agency (EPA) to mean about 2-plus years from now. Although the Hazardous Waste Electronic Manifest Act (October 5, 2012) required the e-Manifest system to be able to be used by any user by October 5, 2015, that date has come and gone. EPA’s goal now is to have the e-Manifest system fully online no later than spring 2018. So the paper form is still alive and well for at least 2 years and still presents the same questions concerning its correct completion. Let’s review a few questions that can stump even the most experienced hazardous waste generator.

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Manifest errors

What if you make an error completing the manifest? Although a generator is required to prepare an accurate and legible manifest, the federal regulations do not address how a generator may correct an incorrect entry once it is placed on the manifest and before the manifested shipment leaves the generator’s site. That said, there are no federal regulations that prohibit a generator from neatly drawing a line through the incorrect information and entering the information correctly. This is a fairly common practice along with initialing and dating the change. Make sure you write hard enough to make the changes on all manifest copies. The manifest is not an official document until the generator/offeror has signed it. If you notice an error after it has been signed, it is a good idea to notify all other signatories, get their approval, and document that you have taken these actions.

Transporter signatures

 How many transporters need to sign the manifest? This question comes up when  there is a second and different driver from the same company who, at the transfer facility, takes possession of the shipment from the first driver who signed the manifest as Transporter 1. Only one signature per transporter company is required, not one signature per driver. The EPA Form 8700-22 instructions for Item 17 state, “only one signature per transportation is required. Signatures are not required to track the movement of wastes in and out of transfer facilities, unless there is a change of custody between transporters.”

Gross or net weight

Should gross or net weight be used on the manifest? The manifest instructions specifically state that the quantity of hazardous waste recorded in Item 11 be based on “actual measurements or reasonably accurate estimates of actual quantities shipped.” If possible, the weight of only the waste itself should be recorded on the manifest. The container capacities should not be used, as the instructions note “container capacities are not acceptable as estimates.”

Waste codes

There are six boxes in Item 13 for waste codes—must all boxes be filled in? You can list multiple Resource Conservation and Recovery Act (RCRA) waste codes, but not all RCRA waste codes must be listed, just those that are most applicable. If your waste is neither a federally listed nor characteristic hazardous waste, it may be a “state only” hazardous waste. Such state specific waste codes for which there are no federal equivalents should be used on the manifest in Item 13 when applicable. No waste codes, either federal or state, should ever be entered in Item 14, which is for “Special Handling and Additional Information.”

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