DEEP: H/W Manifest Requirements

Hazardous Waste Manifest Requirements

Purpose
This fact sheet answers general questions and provides basic information on hazardous waste manifest requirements, and is not intended to supersede the applicable regulations. The hazardous waste manifest requirements are found in Section 22a-449(c)-102 of the Regulations of Connecticut State Agencies ("RCSA"), incorporating Subparts B and D of Title 40 of the Code of Federal Regulations part 262 (40 CFR 262).

Applicability
A generator who transports, or offers for transportation, hazardous waste for off-site treatment, storage or disposal must prepare a manifest to accompany such shipment. Connecticutís requirements are more stringent than those at the federal level. For example, both small quantity and large quantity generators in Connecticut are subject to all manifest requirements. In addition, small quantity generators in Connecticut are not exempted from manifest requirements when they have a contractual agreement with a reclaimer. Conditionally exempt small quantity generators are not currently required to use manifests provided that they do not accumulate more than 1,000 kg (2,200 Lbs) of hazardous waste or 1 kg of any acute hazardous waste at the site.

How to Obtain a Manifest
Many waste transporters provide manifests for the waste shipments that they handle.  Generators may also obtain a list of approved providers of manifest forms from the Federal EPA website.

How to Prepare a Manifest
Instructions on how to fill out a hazardous waste manifest and distribute copies can be found on the back of each manifest. These instruction may also be viewed on the Federal EPA website.

How to Use the Manifest
The generator must:

(1) completely and legibly fill out, or assure the correctness, of all items;

(2) sign the manifest certification by hand;

(3) obtain the handwritten signature of the transporter and the date of waste acceptance on the manifest; 

(4) make a legible photocopy of the signed form; and 

(5) retain and distribute copies as indicated on the back of the manifest document. 

Please note, that generators located in Connecticut, must make a legible photocopy of the completed manifest and send it, (postmarked within seven (7) days of the shipping date) to the Department at the following address:

Hazardous Waste Manifest Program
Department of Energy & Environmental Protection
79 Elm Street
Hartford, CT  06106-5127

Non-RCRA hazardous Wastes
With the exception of regulated PCB wastes (CFR 761.207 - 761.215) including CR01 wastes, the Department does not require generators or transporters of non-RCRA hazardous wastes to use a manifest. Many of the facilities receiving these wastes, however, have record keeping conditions in their permits which require the permittee to use a manifest for all wastes received at the facility. While the permit requirements to retain copies of manifests on-site remain unchanged, copies of manifests for CR02-CR05 wastes should not be submitted to the Department. A letter was sent documenting this policy.

Manifest Record Retention Requirements
A generator must retain a signed copy of the manifest for each shipment for at least three years. The original copy serves this purpose until he/she receives a signed copy from the designated (receiving) facility as confirmation of delivery. The copy received from the designated facility should be kept by the generator for at least three years from the date the waste was accepted by the initial transporter.

Additional record keeping requirements apply if a generator does not receive confirmation from the designated facility. 

If a large quantity generator does not receive a confirmation of delivery (a signed copy of the manifest from the designated facility) within 35 days of the date the waste was accepted by the initial transporter, he/she is required to contact the transporter and/or the designated facility to determine the status of the hazardous waste. 

If the large quantity generator does not receive a confirmation of delivery (a signed copy of the manifest from the designated facility) within 45 days of the date the waste was accepted by the initial transporter, he/she must submit an Exception Report to the Commissioner. The Exception Report shall include: (1) a legible copy of the manifest for the waste for which there is no confirmation of delivery; and (2) a cover letter signed by the generator or the generatorís designate detailing the efforts taken to locate the hazardous waste in question and the results of such efforts.

If a small quantity generator does not receive a confirmation of delivery (a signed copy of the manifest from the designated facility) within 60 days from the date the waste was accepted by the initial transporter, he/she must submit to the Commissioner a legible copy of the manifest with some indication that the confirmation of delivery was not received.

How to Obtain Additional Help on The Use of Manifests
After reading this fact sheet and the instructions on the back of the manifest document, should you still have any questions on hazardous waste manifests, please see the EPA website or contact DEEP staff at (860) 424-3023.

Other Requirements
A generator shipping a hazardous waste restricted from land disposal under 40 CFR 268 must appropriately fill out a Land Disposal Restriction (LDR) notification form which must accompany the waste shipment. Waste haulers routinely offer an LDR form to their clients whenever it is needed. If you have any questions on the LDR requirements, contact DEEP staff at (860) 424-3023.

This overview is designed to answer general questions and provide basic information. You should refer to the appropriate statutes and regulations for specific regulatory language.  It is your responsibility to comply with all applicable laws and regulations.

Content Last Updated November 5, 2014