New Hazardous Waste Manifest

The U.S. EPA has established a new Hazardous Waste Manifest. There will no longer be state specific manifests.

Beginning September 5, 2006, use of the new waste manifest is required. Until then, only the old manifests can be used; and they become void on September 5 regardless of fees paid.

Your waste disposal company should be able to provide the new manifests, or they can also be purchased from certified outlets such as the Illinois EPA. The Illinois EPA charges $3 for each manifest.

The new EPA regulations also cover other issues besides the format.

• It is not acceptable to report total gallons based on the maximum capacity of the drums. If the drum is not full, the actual gallonage must be entered on the manifest, or use the actual pounds instead. The EPA accepts a good faith effort to estimate quantities shipped.
• Significant difference in quantity or type of waste are manifest discrepancies, with specific requirements for resolution. This includes the discrepancy in total piece count of one drum in a truckload, or for a bulk shipment, a variation greater than 10 percent by weight.
• The EPA does not want decimals or fractions for the waste quantity. So not 1½ ton, but instead show 3000 pounds.
• The manifest now has a designated space for an Emergency Response phone number.

The new manifest has significant changes. You can expect that it will take extra time to fill it out at first. If you would like help, please call our office.

Admiral Environmental Services can help you determine if your facility is subject to the fee. We can also prepare the annual report.

If you have any questions, please contact us.

Philip A Twomey, PE
President