Although it was the intent of the rule to try to minimize the practice of entering any and all possible waste codes that might be implicated for a waste stream, we believe generators will use Item 14 to list items of significance to them, such as waste profile data and Emergency Response manual codes. So, if a generator wishes to include additional waste codes in Item 14, they can do so. However, states cannot use Item 14 to mandate the inclusion of additional waste codes beyond the "six per waste stream" that are required in Item 13. Please be aware that the manifest serves as a transportation tracking document rather than a full report of all waste codes. Therefore, the limitation of waste codes applicable to the manifest does not apply to other reporting documents that are federally required by EPA. Therefore, generators and treatment, storage, and disposal facilities are not excused from the reporting requirements of the “mixture and derived-from” rule, the Land Disposal Restrictions (LDR), nor any other waste characterization or testing requirement that generators or facilities may be subject to in order to profile, treat, or manage their wastes.
According to the instructions for Item 13 of the new manifest regarding the waste code fields, up to six federal and state waste codes may be recorded in the spaces provided. See 40 CFR Part 262, Appendix, Instruction 13. If a generator has more than six
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