Manifest Rules

From the archives of the Enforcement and Compliance Listserv for Hazardous Waste Generators

Aug. 29, 2007

Container Weight on the Manifest.

To correctly fill out the Uniform Hazardous Waste Manifest, the weight of
the entire container, waste, packaging, etc. must be recorded on the
manifest. The weight including container is also used to determine if the
hazardous waste equals or exceeds the reportable quantity. For more
information on the Uniform Hazardous Waste Manifest, visit
www.dnr.mo.gov/env/hwp/enf/manifest-rules.htm.

November 3, 2006

Cracking the code on the new Federal Uniform Hazardous Waste Manifest

After a look at the new manifest you may be wondering where to start when it comes to codes. What codes do I record? Where? How many? How does this affect the hazardous waste management process? The new federal uniform hazardous waste manifest implemented on Sept. 5, 2006, requires two types of codes:

Waste Codes - Waste codes should look familiar to most of you since they are exactly the same as before the September 5, 2006, change. In fact, state specific Waste Codes, for which there are no federal equivalents, are the only state information required on the new manifest at this time. These are M001 through M012 for PCB wastes, MH02 for dioxin waste, D096 for the disposal of used oil with less than 50 ppm PCB's and D098 for the disposal of used oil. Please refer to Missouri Hazardous Waste Regulations 10 CSR 25 Chapters 4, 11, and 13 for detailed descriptions of each waste code. Waste Codes can be found in item thirteen on the new manifest. The obvious difference is that the uniform manifest accommodates six waste codes for each waste, whereas the old Missouri manifest allowed for only two. This does not mean that there will always be multiple descriptions for each waste. The extra space simply allow for a more detailed description of wastes that may be characterized by more than one or two waste codes. The Code of State Regulations will eventually be modified to incorporate the federal regulations concerning the new manifest. Visit Missouri's proposed manifest rule for more information.

Management Method Codes - Management method codes are filled out by a representative of the designated treatment facility. These codes are found in item nineteen of the uniform manifest and describe the types of treatment, disposal, and/or recycling the waste has undergone at the designated facility. These codes provide a specific description of what is happening to your waste. Only one code that best describes the way each waste is managed should be designated. After you receive the copy of your manifest back from the treatment facility, you can figure out what specifically happened to your waste. For example, if the treatment facility used the management method code H020, that means your waste solvent was distilled for solvent recovery. See the U.S. Environmental Protection Agency's (EPA) List of Management Method Codes PDF for the entire listing.  The Management Method Code has also replaced the Final Handling Code on the Generator’s Hazardous Waste Summary Report.

The bottom line is the codes are here to help. By clearly understanding the contents of your waste, the designated treatment facility can more easily and efficiently process your waste. In return you receive the peace of mind knowing that your hazardous waste management procedures have improved by simply taking the time to crack the manifest code!

Visit EPA's web site on Hazardous Waste Manifest System.  Also, there is an informative training video available from the Printer's National Environmental Assistance Center.

July 27, 2006

Do not forget to order your new uniform manifests. The federal regulation that replaces current state manifests with the new uniform manifests goes into effect September 5, 2006. The Uniform Hazardous Waste Manifest regulation standardizes the manifest form for the entire country. The new regulation also ensures each manifest has a unique, sequential tracking number, better correlation with the U.S. Department of Transportation (DOT) regulations, and helps track manifest discrepancies. The standardized form will have fields that include wastes codes, an emergency response phone number and a manifest tracking number. If needed, international shipment information and hazardous waste report management method codes can be filled out on the manifest. The new form will no longer have a location for the Missouri generator identification number. You may still use state specific waste codes on the form - for example, in Missouri waste used oil has a code of D098. You may contact the approved printers or your current hazardous waste transporter to obtain the new manifests. You will no longer be able to order hazardous waste manifests from the Missouri Department of Natural Resources.

June 1, 2006

Manifest Update!

Printers for the uniform hazardous waste transportation manifests have been approved! Contact information for the newly approved printers is on the U.S. Environmental Protection Agency's manifest information. For more information on the changes to hazardous waste manifests, including when the switch to the new manifest will occur, please review our two previous listservs on the topic below.

April 13, 2006

The New Uniform Manifest

There are big changes coming down the road for your hazardous waste manifests. On September 5, 2006, your business will be required to use the new Federal Uniform Manifest.  According to the US EPA's website, fourteen companies as of March 27, 2006, have applied for approval to print the new uniform manifests. Although there are currently no approved printers for the uniform manifest, it is a good idea to start thinking about using up your current stash of manifests and scheduling a waste shipment before the September 5, 2006, date. If your business is a small quantity generator you will have 180 days (or 270 days if your waste is transported more than 200 miles) before you must ship again. If your business is a large quantity generator you will have 90 days before you must ship again. Because this is such a large, industry-wide change, it is a good idea for your business to be proactive. Bookmark the US Environmental Protection Agency's manifest information and check it frequently to see if printers have been approved. Once approved printers are available, order your manifests early to ensure you receive them by September 5, 2006. Contact your licensed hazardous waste transporter and to learn if they have new procedures or updates. It might be a good idea to avoid potential problems in the new system by scheduling your waste removal prior to the early September rush. As always, this listserv will notify you of any changes or updates.

E-Scrap Stakeholders Workgroup

If you are receiving this listserv, you have a computer. Electronic waste or E-Scrap is an important and complex issue. Our first E-Scrap Stakeholders Workgroup on February 24, 2006, was very successful. If you are interested in participating, know anyone who would be interested in participating, or would simply like to see what we are working on, visit E-Scrap Stakeholder Workgroup.  The next E-Scrap Stakeholder meeting is Wednesday, April 19, 2006, from 9:00 a.m. to 4:00 p.m. at the Elm Street Conference Center, 1738 E. Elm Street, Jefferson City, Missouri (see map for location). The primary purpose of the E-Scrap Stakeholder Workgroup is to determine the framework for how E-Scrap is disposed, reused, and recycled without threat to the environment and in an economically sustainable fashion. Please contact Mike Menneke or Heidi Rice at 573-751-3176 for more information.

Nov. 30, 2005

In case you hadn't heard, the Environmental Protection Agency (EPA) has overhauled the current hazardous waste shipping manifests. No longer will companies that operate in multiple states need to learn and use multiple types of state manifests.  The Uniform Hazardous Waste Manifest regulations standardizes the manifest form, insures each manifest has a unique tracking number, better correlate manifests with U.S. Department of Transportation (DOT) regulations and helps track manifest discrepancies. The standardized form will have fields that include wastes codes, emergency response phone number, manifest tracking number, international shipment information and hazardous waste report mangagement method codes. The new form will no longer have a location for the Missouri generator identification number. You may still use state specific waste codes on the form, for example in Missouri waste used oil has a code of D098.

Although no one is required to use the new uniform manifest until Sept. 5, 2006, we thought you might want to know about upcoming changes. Please continue to use up your current stock of manifests. Keep in mind that once Sept. 5, 2006, arrives you will no longer be able to use old manifests so you may not want to stock up! If you are about to run out of the old ones you may wish to switch over to the new form if available from your transporter or treatment facility.

EPA Links

This information may generate more questions. Please e-mail your questions on manifesting and they will be addressed in future listservs.

If you know of anyone who would like to be added to this listserv, visit MoDNR Enforcement and Compliance Assistance Newsletter Generators Subscription to sign up.

If you need further assistance, please e-mail or contact the Department of Natural Resources' Hazardous Waste Program at 573-751-7560 or 800-361-4827.

Return to listserv topics at MoDNR Hazardous Waste Generator Archive.