Changes to the Uniform Hazardous Waste Manifest

According to the U.S. EPA, the recent changes have two main purposes:

•  Establish a single form that can be used nationwide. This will reduce the burden on transporters who operate in more than one state, and



•  Improve the tracking of "problem wastes" for example, hazardous waste that destination facilities reject, waste residues from hazardous waste containers that were not completely empty, or wastes entering or leaving the United States.

The specific changes to the manifest forms include:

•  All state optional fields have been removed with the exception of the waste code and management code fields. The waste code and management codes are no longer optional. All fields are now required. The waste code field allows state specific waste codes as long as the state code is not redundant of the EPA code;



•  Regulations have been added to instruct hazardous waste handlers on how to handle rejected loads or containers that are not empty according to the definition of empty containers. Fields have been added to the manifest in the Discrepancy box to track this information. In addition, a block has been added to capture alternate facility information and signature. This new block can also be used to reject waste back to the generator according to the new rejected load regulations. IMPORTANT NOTE: rejected loads staged by the generator should be labeled as such as it can affect RCRA accumulation rates but should not affect monthly generation rates.
  
  
•  An international shipments block was created to specifically collect import/export information. This information was previously written in the additional description block on the old manifest;



•  The definition of empty containers was changed to be consistent with the U.S. DOT's definition;



•  Other changes made to the manifest include generator block; emergency response phone number block; the U.S. DOT description block; special handling instructions and additional information block; and the waste minimization certification;



•  Some of the manifest instructions have been clarified such as properly reporting total quantity and unit of measure on the manifest; and



•  In addition some regulations have been expanded due to the new rejected load regulations and the change to the empty container definition. The expanded regulations include manifest discrepancies and manifest copy distribution. GENERAL RULE: a second manifest is needed to re-ship rejected loads.