Hazardous Waste Manifests: FAQ For California Generators

Think of a hazardous waste manifest as the roadmap for your hazardous waste journey. Just as a map guides travelers from their starting point to their destination, the manifest charts the path of hazardous materials from your facility to its final disposal. 

This required document ensures that every step of the waste management process is navigated with accuracy and follows both federal and state regulations.

Whether you're a manufacturer, healthcare provider, or any business generating hazardous waste, understanding how to effectively manage and complete your manifest is important for staying compliant and safeguarding the environment. 

If you’re a hazardous waste generator in California, here are some questions you may have about manifests:

• What is a hazardous waste manifest?
• Who needs to use a hazardous waste manifest in California? 
• What information is required?
• How do I complete a hazardous waste manifest?
• What is the e-Manifest System?
• How long do I need to retain hazardous waste manifests?
• What should I do if there’s an error on the manifest?
• Can I transport hazardous waste without a manifest?
• Are there any exemptions to the manifest requirement?
• How can I get help completing a manifest?

What Is A Hazardous Waste Manifest?

A hazardous waste manifest is a legal document required by the Environmental Protection Agency (EPA) that tracks hazardous waste from its origin to its final disposal. The manifest serves as a record for all parties involved in the waste management process, including the generator, transporter, and disposal facility. It ensures that hazardous waste is managed responsibly and according to federal and state regulations.

Who Needs To Use A Hazardous Waste Manifest In California?

Any business or entity in California that generates hazardous waste must use a hazardous waste manifest. This includes industries such as manufacturing, healthcare, automotive, pharmaceuticals, laboratories, agricultural businesses, and more.

What Information Is Required?

The hazardous waste manifest requires detailed and accurate information to ensure the proper tracking and management of the waste. The key details that must be included are:

1. Generator's Information: This includes the name, address, and EPA Identification Number of the business or entity generating the waste.
2. Transporter’s Details: The name, address, and EPA Identification Number of the company responsible for transporting the hazardous waste to its final destination.
3. Waste Description: A detailed description of the hazardous waste, including the waste codes, physical and chemical properties, and any special handling instructions. The manifest must also include the quantity of waste, typically measured in gallons, pounds or cubic yards.
4. Containers and Packaging: Information on the type and number of containers used for the waste, as well as the method of packaging, such as drums, tanks or bulk packaging.
5. Designated Facility Information: The name, address, and EPA Identification Number of the Treatment, Storage or Disposal Facility (TSDF) where the waste will be processed or disposed of.
6. Signatures and Dates: The manifest requires signatures from the generator, transporter, and receiving facility, along with the dates of transfer, to confirm the chain of custody and the responsible parties at each stage.
7. Emergency Contact Information: Contact details for the person to be reached in case of an emergency during the transportation of the hazardous waste.
8. Manifest Tracking Number: A unique manifest tracking number is assigned to each shipment, which is used to monitor the waste through the entire process from generation to disposal.

Ensuring that all information is complete, accurate, and up to date is crucial to maintain compliance with both federal and state regulations. Errors or omissions on the manifest can lead to significant penalties and delays in the waste disposal process.

How Do I Complete A Hazardous Waste Manifest?

Completing a hazardous waste manifest involves filling out all necessary sections with accurate information about the waste, the generator, the transporter, and the TSDF. California generators must ensure that their manifests comply with both federal and state requirements, including the use of the EPA’s e-Manifest system when applicable.

What Is The e-Manifest System?

The e-Manifest system is a national electronic tracking system for hazardous waste shipments managed by the EPA. In California, the use of the e-Manifest system is mandatory for most hazardous waste shipments. Electronic manifests allow for the electronic submission, tracking and record-keeping of these documents.

How Long Do I Need To Retain Hazardous Waste Manifests?

In California, generators must retain copies of hazardous waste manifests for at least three years from the date of shipment. However, it is often recommended to keep them longer to ensure compliance with all regulatory requirements.

What Should I Do If There’s An Error On The Manifest?

If you identify an error on the hazardous waste manifest, it should be corrected promptly. If the error is found before the waste is shipped, a new manifest should be created. If the error is discovered after shipment, the generator must notify the transporter and TSDF to correct the record.

Can I Transport Hazardous Waste Without A Manifest?

No, transporting hazardous waste without a manifest is illegal in California and can result in severe penalties. The manifest serves as a key component of the cradle-to-grave tracking of hazardous waste.

Are There Any Exemptions To The Manifest Requirement?

Certain types of hazardous waste or specific quantities might be exempt from manifesting requirements under California regulations. However, these exemptions are limited and typically apply to small-quantity generators or specific waste streams. It’s important to verify if your waste qualifies for any exemptions.

How Can I Get Help Completing A Manifest?

The Department of Toxic Substances Control offers several links on its Managing Hazardous Waste page that provide more information about manifest requirements. 

An experienced hazardous waste transporter also can assist you in filling out a manifest. While it is the generator's responsibility to ensure the manifest is complete and accurate, transporters often have extensive experience with the manifesting process and can provide guidance. 

Disposal companies can help ensure that the information related to the transportation and disposal of the waste is correctly entered, including details about the transporter and the receiving facility. However, it's crucial that the generator reviews and approves all information on the manifest before signing, as they are ultimately responsible for its accuracy and compliance with regulations.