Frequent Questions

Is a manifest required during the transport of hazardous waste on a public road within or along a contiguous piece of property owned by the same person (i.e., a university)?

Manifests are not required for shipments of hazardous waste on rights-of-way on or between contiguous properties, or along the perimeter of contiguous properties controlled by the same person (40 CFR §262.20(f)). Manifests are also not required for hazardous waste shipments between non-contiguous properties controlled by the same person, and connected by a private right-of-way to which the public does not have access (62 FR 6621, 6645; February 12, 1997). 

Additional guidance regarding manifest requirements for transportation within or along contiguous property is available in the following documents: 

Monthly Call Center Report Question; April 1999 (RCRA Online #14343
Monthly Call Center Report Question; September 1989 (RCRA Online #13315

These documents are available at the following URL: 

https://yosemite.epa.gov/osw/rcra.nsf/how+to+use?OpenForm

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