Frequent Questions

Are generators required to list all hazardous waste codes on the Hazardous Waste Manifest?

In the recent past, EPA did not require hazardous waste generators to record waste code information on the manifest. EPA deferred to state agencies to properly instruct generators on which federal and state waste codes to report on the manifest for RCRA regulated wastes and state-only regulated hazardous waste, respectively. Consequently, the number and type of waste codes recorded on the manifest varied from state-to-state.

In March 2005, EPA standardized the content and appearance of the manifest form and also limited the number of federal and state waste codes that could be reported on the form. (See March 4, 2005 Federal Register (70 FR 10776)). Under the new manifest system that became effective on September 5, 2006, a hazardous waste generator may report up to six federal and state waste codes in Item 13 for each waste stream identified in Item 9b of the new manifest. The federal RCRA waste codes are understood nationwide, so in cases where a state code entirely duplicates a federal code for a RCRA hazardous waste, the federal code must be used. Thus, state waste codes must be entered on the revised form to describe state regulated hazardous waste and RCRA hazardous waste for which the state waste code conveys additional information not conveyed by the corresponding federal code.

A generator is allowed to exercise his or her own judgment when ascertaining which waste codes to report, but the waste codes entered on the manifest should be the most representative of a waste. In addition, a generator may report additional waste codes in the “Additional Description and Special Handling” box (i.e., item 14) on the new manifest; however, the state implementing agency cannot require the generator to enter the additional waste code information in that box.

Additional information can be found in the following guidance memoranda:

Memo, Bussard to Kuhn; June 19, 1996 (RO 14033)
Monthly Call Center Report Question; April 1996 (RO 13782)
Memo, Lowrance to Citizen; April 29, 1993 (RO 11741)
Memo, Barnes to Simon; November 17, 1989 (RO 11480)
Memo, Williams to Manthey; August 19, 1987 (RO 11281)
Monthly Call Center Report Question; August 1987 (RO 13002)
Memo, Straus to Slemmer; November 17, 1986 (RO 11196)
 
These memoranda are available in the RCRA Online database at the following URL: https://yosemite.epa.gov/osw/rcra.nsf/how+to+use?OpenForm.

 

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