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Manifest Form Frequent Questions
1. In the case of hazardous waste imports, the regulation at 40 CFR 262.60(b)(1) requires a person to enter the importer’s name, address, and EPA Identification number, as well as the foreign generator’s name and address, in the generator identification block of the manifest. The new form contains two distinct address fields (i.e., the “Generator’s Name and Mailing Address” and “Generator’s Site Address”) within the generator identification block, but the rule does not designate either field for the importer and foreign generator’s information. Please clarify where the importer and foreign generator’s information must be entered in the generator identification block.
EPA recommends the following approach in entering on the manifest the appropriate importer and foreign generator information. The importer’s address should correspond to the importer’s corporate office where signed copies of the import manifests are collected and managed. The foreign generator’s address should correspond to the actual physical site address from which the import shipment originated. Therefore, the importer’s name and mailing address should be entered into the “Generator’s Name and Mailing Address” field, and the foreign generator’s information should be entered into the “Generator’s Site Address” field of the generator identification block.
2. Are generators required to use all six copies of the manifest? Realistically, generators may only need 4 copies of the manifest to track intra-state shipments, but the copy distribution scheme in the margins of the new form identifies a use for all six copies.
No. The copy distribution scheme in the form margins is advisory, and the marginal entries do not impose any new requirements to submit copies to generator or destination states. Copy submission requirements are governed by state law only, and if states do not require the submission of manifest copies, those copies that are earmarked to states can be discarded or used in lieu of other copies.
3. 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 waste codes for a particular waste, may they use Item 14, “Special Handling Instructions and Additional Information,” for the additional federal codes?
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.
4. Some states have developed abbreviated manifest forms for some of its state-only hazardous waste. How will state-only waste manifests be affected by the new rule?
The new manifest form and continuation sheet are 6-part forms, and States must use the new form for federal and state-only waste shipments. Thus, states cannot require use of a 2-part or 4-part manifest for its state-only wastes, and waste handlers can discard any remaining copies of the federal manifest that are not used for a shipment.
