Universal waste regulations do not require small or large quantity handlers of universal waste to use a manifest for transportation off site. Small quantity handlers of universal waste are not required to keep records of their off-site shipments (Section 273.19). Large quantity handlers of universal waste must follow the tracking requirements in Section 273.39, which include keeping a record of each off-site shipment of universal waste from the handler to other facilities. The record may take the form of a log, invoice, manifest, bill of lading, or other shipping document.
Additional clarification can be found in the following guidance document:
Monthly Call Center Report Question, May 1998 (RCRA Online #14273)