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In the United States the management of hazardous waste is regulated from "cradle to grave" except for exempt low risk activities such as hazardous materials in household trash. The waste manifest is the tool that ensures and documents proper disposal. The waste manifest is required for shipping or disposing of RCRA regulated wastes and special wastes regulated by some states. Although the manifest is called the "Uniform Waste Manifest" there is nothing uniform about it as states developed their on forms based on the basic form created by the U.S. Environmental Protection Agency (EPA). But that is about to change.
The EPA proposed a rule on manifest reform that was published in the Federal Register on May 22, 2001. That proposal was aimed at standardizing the "uniform" hazardous waste manifest as one unique form for nationwide use in the U.S.; and creating an electronic version of the manifest. In responding to public and industry comments, EPA decided to separate the two different manifest issues. The manifest revisions were finalized in the March 4, 2005 final rule and the electronic manifest rule ["e-manifest"] was deferred until later. The June 10 rule made corrections to the March 4 final rule.
The manifest revisions rule will become effective in all states on September 6, 2005. (RCRA authorized states will be required to adopt the changes in their state programs.)
The rule standardizes the manifest form, eliminates state variations, and prevents states from making changes to the form. Changes relating to the form include:
EPA provided a delayed compliance date for the new manifest form and procedures in order to allow manifest users, states and form printers to prepare for the changes. During the transition period, handlers and states will use only the old form. After September 5, 2006, only the new manifest form and requirements established under this final rule will be valid and acceptable for use.
Handlers will obtain new forms from any source that has registered with 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. EPA will maintain a list of entities that have been approved to print/distribute the form, so that the public may acquire the forms from one of the approved printers. Some large waste firms are expected to register to print their own forms, so that they can use them wherever they do business, instead of having to buy manifests from different states (the current practice). States may also register to print the new form, but state rules cannot establish the state as the exclusive source of forms.
The final rule made the following additional changes to the Federal hazardous waste regulations:
The EPA action affects generators, transporters and waste facilities
that handle hazardous waste. They must comply with the revised rule. In the long run, the manifest
standardization should save manifest preparation time and reduce the possibility of errors due to
not having to comply with several manifest variations.
Persons preparing manifests or arranging for the disposal of hazardous waste should always be aware of any specific manifest handling requirements of their destination state and their own generation state before obtaining manifest forms. In addition, they will need to work with their destination facilities to determine the proper handling codes for their wastes (item 19 on the new manifest) and to ascertain if any wastes are hazardous at the state level that are not regulated as hazardous at the Federal level. In addition to generators, carriers and receiving facilities will need to become familiar with the new manifest procedures.
More information